MANAGEMENT OF THE INSTALLATION Cadbury Ireland Limited Project Ref: OES1061_01 EPA Export 25-07-2013:21:15:11
Site Management and Control Cadbury Ireland Limited manufactures and distributes over 25 products within the Irish Market and exports a number of key lines to Cadbury Limited U.K. and global markets. Cadbury Ireland Limited has core operations in Ireland, the UK and Europe, serving local and global markets. Cadbury Ireland Limited,, is an international provider of milk chocolate crumb. This is an intermediate product utilised in the production of milk chocolate in a number of facilities throughout the world. The Head of Manufacturing holds overall responsibility for Environmental management and control at the Cadbury Ireland Limited,, site. The Quality, Environment, Health and Safety (QEHS) Manager holds responsibility for the day to day management of environmental issues at the site. Cadbury Ireland Limited,, has a structured management approach to the operation of the business in terms of product quality, process control, environment, safety, training and analytical capability. Central to this structured approach is the quality management system. This provides a structured framework for operational management at the installation. An environmental management system provides a similar framework for the maintenance and improvement of the environmental performance at the site. Both quality and environmental management systems are audited on an ongoing basis, both internally and as part of third party verification. The environmental management system is certified to the ISO14001 Environmental Management System specification by NSAI (National Standards Authority of Ireland). The organisational structure at the plant is illustrated diagrammatically on Appendix C1. OES Consulting Page 1 of 14 EPA Export 25-07-2013:21:15:11
C1 Management Structure Environmental management and control at the Cadbury Ireland Limited, Rathmore Installation, is the overall responsibility of the Head of Manufacturing. The Head of Manufacturing reports directly to the Production Director of Cadbury Ireland (Dublin) Limited and has overall responsibility for all site matters, including quality and the environment. The key responsibilities of the Head of Manufacturing include: Ensuring that the Company Quality and Environmental Policy is understood implemented and maintained. Ensuring that trained personnel are available for testing and verification activities Ensuring the company Policy Statement is communicated to all site personnel. The QEHS Manager is the designated Management Representative and is responsible for maintaining the quality system as described in the Quality Manual and the environmental system as described in the Environmental Manual. The QEHS Manager is responsible for the laboratory function including the issuing of recipes and for particular sections of the documented quality and environmental systems. In addition the QEHS Manager liaises with customers, suppliers and interested parties on quality and environmental issues, including the environmental emergency response procedure, disposal of non-conforming products, container transport and stores approval, internal quality and environmental system audits and positive release of product. The QEHS Manager is responsible for maintenance of training, Environmental and Health and Safety records and ensuring that key personnel policies regarding safety, hygiene, quality and environmental are understood by all employees. The Production Engineer is responsible for the Engineering function on the facility site and for ensuring that all engineering personnel understand and adhere to the Company Quality and Environmental System. The Production Engineer is responsible for maintenance of all plant equipment and buildings on the site and calibration of plant equipment where necessary. The Engineering Manager reports to the Production Engineer. The Production Engineer is responsible for the environmental emergency response procedure. Environmental management falls under the responsibility of the QEHS Manager who deals with environmental management issues on a day to day basis. The QEHS Manager is assisted by a laboratory team, waste water treatment plant operators, and security personnel. The relationship of the organisational structure to environmental management at the plant is shown on Appendix C1. In general, all staff at the facility have a responsibility for ensuring that environmental requirements are met. There is one full time employee assigned to the management of the Waste Water Treatment Plant, and one with relief support provided as required. The treatment of effluent is monitored on a daily basis and recorded in a daily log manual. The QEHS is responsible for the wastewater control and treatment, and informs the shift and area managers of the operations of the plant including objectives and specified target loadings. The responsibilities of the environmental team can be broadly divided into two main areas: 1. Resource Use and Energy Efficiency Management. 2. Waste Water Treatment and Waste Management. OES Consulting Page 2 of 14
Resource Use and Energy Efficiency Management The areas of responsibility include: The reduction of energy consumption. Maintenance and monitoring of an Energy Conservation Programme. Waste Water Treatment and Waste Management Areas of responsibility include: Operation of wastewater treatment plant. Monitoring of loadings from individual plant areas. Evaluation of waste water results. Disposal of all solid waste Increase opportunities for recycling throughout the plant. OES Consulting Page 3 of 14
C2 Management & Responsibility for operation and control of onsite abatement and treatment systems The QEHS Manager reports to the Head of Manufacturing who has overall responsibility for maintenance and implementation of the Environmental Management System (EMS), including the compilation, distribution, amendment and maintenance of all EMS documentation at the Cadbury Ireland Limited,. Specifically, the main duties and responsibilities of the QEHS Manager are as follows: (i) (ii) (iii) (iv) (v) (vi) (vii) (viii) (ix) (x) (xi) (xii) Establishing and documenting the environmental standards and criteria to be applied for each production and process. Ensuring that the responsibility of each department for environmental issues is suitably documented. Ensuring that adequate records are maintained for demonstration of conformance to environmental requirements. Conducting internal audits of the Environmental Management System to ensure continued adherence to documented requirements. Monitoring non-conformances within the environmental system. Ensuring that adequate resources are available to maintain the environmental system at the required level. Ensuring the Health and Safety Regulations are catered for in the Environmental Management System. Ensuring the quality management system objectives are incorporated into the Quality Management System. Maintaining a library of environmental literature and documentation. Assisting in internal dissemination of environmental information. Providing a point of contact for communication and correspondence with the EPA Implementing environmental projects at the plant. All new employees at the installation receive an environmental induction, and depending on requirements, external and internal training courses are given as required. OES Consulting Page 4 of 14
C3 Calibration & Maintenance Systems The Engineering Manager has overall responsibility for the plant preventative maintenance (PM) programme. Included in the plant PM programme are: Waste water treatment plant equipment. Air handling units. Boilers and equipment. Where backup or standby plant is not kept, consumable spares are kept for identified critical equipment including: Production plant and equipment Incoming water treatment equipment Waste water treatment equipment Air emissions abatement equipment All items of plant equipment included in the overall site maintenance programme are individually numbered and tracked. The Maintenance Management System is described in detail below: Maintenance Objective To achieve the agreed plant operating pattern, product output and quality within the accepted plant conditions and safety standards at the minimum resource costs. Maintenance Management System Cadbury Ireland Limited,, operates a SAP (Systems Applications Products) computerised maintenance management system (CMMS). The SAP system comprises an integrated computer system which incorporates computer applications throughout the and enables operations to be standardised and integrated into a single information source. The SAP computer system is used as a tool to record work done and to issue jobs from a schedule of work. The Maintenance log contains information pertaining to the inspection of instruments and any maintenance work required or undertaken. Cadbury Ireland Limited,, Quality Management System contains a paper based plant calibration schedule which specifies the reference standards to the applied when calibrating plant instruments and equipment. The schedule details the instrument to be calibrated, the method to be used, and the frequency at which it should be calibrated. It also contains details of the individual responsibility for undertaking the procedure. Maintenance Procedures A Preventative Maintenance Programme designed to meet the needs of the site is in operation. It is based on two categories, Scheduled Maintenance and Inspection Maintenance. Schedule Maintenance is set to hours of operation or statutory requirements. Items for manual maintenance will be dealt with according to availability within each calendar year. Inspection Maintenance is continuously carried out by Maintenance Personnel, Engineering and Plant management and Plant Operators. OES Consulting Page 5 of 14
Unplanned Maintenance Issues are periodically evaluated and the corrective action required is put in place. All items of unplanned maintenance are recorded in the Section Managers report book and the Mechanical Maintenance Section Managers record book. These reports are under continuous review and any items needing more frequent maintenance attention are re-scheduled. PM is designed to increase the reliability of assets and to increase plant availability. A review of the maintenance logs is undertaken on a monthly basis to evaluate and schedule any maintenance work and any calibration requirements. The maintenance work is scheduled to be completed on a phased basis to reduce the requirement for continual maintenance requirements. The Quality Management System is consulted to assign the maintenance work to the responsible individual. Once completed a record of the work undertaken is logged in the maintenance log book. Spare parts are re-ordered on a regular basis and where necessary spare parts in excess of those required are retained onsite to reduce the delays associated with the re-ordering process. C4 Waste Control Systems Cadbury Ireland Limited,, operates a waste management and control system, which is defined by documented standard operating procedures. These are reviewed and updated regularly to reflect up-to-date operations on-site. Where possible, waste is minimised at source through application of best practice manufacturing and processing techniques and loss control systems within processing areas. Throughout the installation, solid waste streams are collected and contained in suitable containers prior to recycling or disposal. The recycling area for the facility is located in the western section of the plant. All wastes are stored within designated storage areas prior to evacuation offsite. In order to ensure the Cadbury Ireland Limited,, maintains a successful waste control programme, the facility has a supplier approval programme. All waste contractors utilised by the facility are obligated to provide Waste Collection Permits. Similarly, Waste Licences are required for waste treatment facilities all of which are inspected to ensure they comply with the specified European Waste Catalogue (EWC) code for the activity in question. Copies of waste certificates are stored and updated on an ongoing basis to ensure that all contractors conform with waste contracts. All Waste Licences and Collection Permits for new waste contractors are reviewed prior to approval to ensure that environmental requirements are in compliance. Cadbury Ireland Limited, has a procedure in place for contractors covering best practice for a food producing factory and environmental aspects. The supplier approval procedure in place ensures that environmental requirements are adequately defined and documented and suppliers of goods and services are on an approved supplier listing. OES Consulting Page 6 of 14
In addition, a copy of the site environmental policy is communicated to all suppliers with a vendor questionnaire including questions on environmental aspects pertaining to their operations. OES Consulting Page 7 of 14
C5 Overview of Quality Control System Cadbury Ireland Limited,, establishes, documents, implements and maintains a quality management system and continually improves its effectiveness in accordance with the requirements of the International Standard ISO 9001:2000. The quality system ensures that all those activities within the organisation that could impact on the quality and safety of the product are consistently defined, documented and effectively implemented. Central to this structured approach is the quality management system, which provides the structured framework for operational and quality control at the plant. The environmental management system provides a similar structured framework for the maintenance and improvement in the environmental performance of the Installation. The Quality System consists of 5 Quality Manuals and 1 Hazard Analysis Critical Control Point Manual. The company plans for quality by means of having these Quality Manuals where necessary, controlled, identified and up-dated as required to ensure quality requirements are met. The Quality Management System (QMS) of Cadbury Ireland Limited,, works on a continual basis to identify the processes requiring quality management and, in turn, to determine the methods required to ensure that both the operation and control of these processes is effective. The QMS system is utilised to: (a) (b) (c) Ensure the availability of resources and information necessary to support the operation and monitoring of these processes Monitor, measure and analyse these processes Implement actions necessary to achieve planned results and continual improvement of these processes. These processes are managed by the organisation in accordance with the requirements of the ISO 9001:2000. The QEHS Manager is responsible for implementation of the quality management system including internal audits, corrective and preventative action and management reviews. All levels of Management have responsibilities under the Quality System to ensure quality is maintained at the plant. The QEHS Manager liaises with external parties e.g. customers, regulatory authorities etc. on quality matters. The responsibility for day-to-day operation of practices and procedures lies with the relevant managers in each area. All environmental procedures are covered under ISO 14001. Copies of the ISO 9001:2000 and ISO 14001 certificates are included in Appendix C2. OES Consulting Page 8 of 14
C6 Quality Control Policy Statement of Cadbury Ireland Limited, OES Consulting Page 9 of 140
C7 Environmental Management System Central to the successful management of environmental issues at the site is the Environmental Management Plan (EMP). The EMP specifies the environmental objectives at each relevant function and level within the organisation. The objectives are communicated to all personnel throughout the facility. Also communicated is the target level of environmental improvement to be achieved within the year. Procedures specifying the environmental performance objectives and targets at all relevant levels within the organisation are established and maintained following an evaluation of the environmental effects of the sites activities, processes, products and services. The objective is to minimise and, wherever possible, eliminate adverse effects. The Environmental Management System of Cadbury Ireland Limited,, is based on a dynamic cyclical process of planning, implementing, assessing and reviewing as can be seen Figure 3.1. Objectives and targets are reviewed on an annual basis through an Environmental Review process. New targets are established on an annual basis which are consistent with the Environmental Policy, and also account for legal requirements. Figure 3.1 Cadbury Ireland Limited Environmental Management System Environmental Management System Review Checking and Corrective Action Cadbury Ireland Ltd. Environmental Policy Environmental Aspects Legal and other Requirements Objectives and Targets Environmental Management Programme Monitoring and Measurement Non-conformance and Corrective and Preventive Action Environmental Management Records Implementation and Operation Structure and Responsibility Training and Awareness and Competence Communication Environmental Management System Documentation Document Control Operational Control The objectives and targets are based on aspects and impacts of the ISO14001 approach and, as a result, they cover the sites total environmental impact. The primary objective is to prevent or eliminate pollution or waste and, where this is not practicable, to reduce or minimise, re-use or recycle before final disposal. The objectives and targets are measurable, focused, and based on the following environmental principles: (a) Reduction of waste at source. OES Consulting Page 10 of 140
(b) (c) (d) (e) Reduction of the use of energy at source. Re-use and recycling to the maximum extent possible of the energy or waste generated. Effective safe treatment and disposal of any non-recoverable wastes. Minimisation of the environmental effects of products during their handling, use and final disposal. An Environmental Management Programme is in place and amended on an annual basis. Environmental site objectives are set based on the Register of significant environmental effects. Each Manager has his own objectives which fit in with the overall site plan. The programme is set out under the following headings: Item Who is responsible? When item is to be completed What action is to be taken? Corrective action is put in place as necessary. Progress is monitored and recorded at the Environmental Meetings. Environmental aspects and impacts are considered when any new plant or programme is being put in place, and the programme is amended where necessary. OES Consulting Page 11 of 140
C8 Cadbury Ireland Limited Environmental Health & Safety Policy Statement OES Consulting Page 12 of 140
C9 Assessment of Environmental Performance Cadbury Ireland Limited,, provides for ongoing assessment of its environmental performance through the environmental projects as outlined in C7 above and as part of the ISO 14001-certified environmental management system. As described in C6 above, Cadbury Ireland Limited,, operates a series of environmental projects. An environmental corrective action system is in place and provides a mechanism by which continuous improvement is achieved. Corrective actions are tracked on a continuous basis and records are maintained under ISO14001. Specific environmental performance indicators are assessed as follows: Improvements in treatment/abatement systems resulting in reduced emissions Cadbury Ireland Limited,, is currently in the process of reviewing the replacement of one of the existing Heavy Fuel Oil (HFO) boilers with the intention of installing a more energy efficient system. The facility is currently in the process of upgrading its underground drainage system. This is being undertaken on a phased basis to replace the old drainage system. Trees have been planted along the northern boundary of the facility to visually screen the development from the surrounding area and facilitate noise reduction. Recovery, reuse, recycling and correct disposal of material on and off-site Recovery and Reuse a. Heat recovery operations are in place to maximize the reuse and recovery of water with the heating system in order to reduce both energy and water consumption. Recycling a. Chocolate crumb which has failed quality control standards is recycled within the process. b. Waste oil is collected and stored and taken away by Atlas Oil, and Lehane Environmental in addition to other approved contractors for recycling. c. Metal is collected by Cork Metal Ltd. for recycling. d. Cardboard is recycled by Killarney Waste Disposal (KWD). Correct Disposal a. Fluorescent light bulbs, and Visual Display Units (VDU) are collected by the Irish Lamp for proper disposal. b. C.O.D. vials are collected by AVR Safeway in addition to other approved waste contracts for proper disposal. c. Sludge is collected by Abbeyross Manufacturing Co. Ltd. (trading as Munster Waste) and disposed of accordingly in Molasin Compost Ltd. in Co. Waterford. OES Consulting Page 13 of 140
Prevention of accidents and the preparation of contingency plans in the event of accident Cadbury Ireland Limited,, has procedures in place to identify and evaluate potential accidents and emergency situations. The procedures cover the prevention and mitigation of the environmental impacts that may be associated with them. These procedures are reviewed and revised as necessary and where practicable tested. Savings in energy and material usage Significant investment has been made in improving energy efficiency at the site. An energy audit is currently being undertaken by an external consultancy as part of a drive towards increasing energy efficiency. The most recent annual Environmental Review Report has shown a significant reduction in energy usage which coincided with an increase in plant production. Employee training Personal training is considered a key function in the successful operation of the installation. All staff members receive an environmental induction, and further training is given as appropriate. Staff assigned environmental duties are provided with on-going training in environmental issues. Complaints recording and investigation only. In accordance with the requirements of the internal ISO14001 procedures, Cadbury Ireland Limited,, logs and investigates purposes all complaints of an environmental nature. In the event of an environmental incident at/or associated with the plant Cadbury Ireland Limited,, inform the appropriate regulatory authorities where necessary. The responsibility of reporting inspection any incidents of investigations from the facility is the responsibility of the QEHS Manager.For OES Consulting Page 14 of 140
Appendix C.1 Company Organisation Chart
Head Head of of Manufacturing Steve Flello Shift Manager Willie Gleeson Physical Logistics Manager Andy Kiely Production Engineer Liam O'Flynn (Site Engineer accountabiilties) Shift Manger Con Lynch Shift Manager Liam Warren Shift Manager Mike O'Connor Shift Manager Joe O'Riordan Office Support Engineering Manager Jim McSweeney Day Based Trades Shift Trades Production Teams QEHS Manager Jocelyn Cathalin Effluent Plant Team (1 Operator and 1 relief Operator) Laboratory Team (6 Technicians) Milk intake Team 1 Operator and 1 relief Operator) Security Two Operators H&S Manager DavidO'Sullivan
Appendix C.2 Copies of Certificates ISO 19001:2000 ISO 14001:1996 OHSAS 18001:1999