Health, Safety and Environment Policy Manual - Tech · PDF fileCompany-Confidential HSE Policy...

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Copyright © 2013, Tech Mahindra. All rights reserved. Health, Safety and Environment Policy Manual Sharda Centre, Off Karve Road, Erandwane, Pune, Maharashtra, India 411004 www.techmahindra.com

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Copyright © 2013, Tech Mahindra. All rights reserved.

Health, Safety and Environment Policy Manual

Sharda Centre, Off Karve Road, Erandwane,

Pune, Maharashtra, India 411004

www.techmahindra.com

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Table of Contents

1 GENERAL .................................................................................................................................................... 3

1.1 SCOPE ............................................................................................................................................................ 3

2 REFERENCE............................................................................................................................................... 3

2.1 STANDARDS ............................................................................................................................................ 4

2.2 GUIDELINES ............................................................................................................................................ 4

2.3 MANUALS ................................................................................................................................................ 4

3 DEFINITIONS AND ABBREVIATIONS .................................................................................................. 4

4 HSE MANAGEMENT SYSTEM ................................................................................................................ 6

4.1 GENERAL REQUIREMENTS ..................................................................................................................... 6

4.2 HSE POLICY ........................................................................................................................................... 6

4.3 PLANNING .............................................................................................................................................. 7

4.3.1 PLANNING FOR ASPECTS/HAZARDS IDENTIFICATION IMPACT/RISK ASSESSMENT AND CONTROL .............. 7

4.3.2 LEGAL AND OTHER REQUIREMENTS ............................................................................................................ 8

4.3.3 HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT PROGRAMME(S) ................................................... 8

4.4 HSE R&R ....................................................................................................................................................... 9

4.4.1 TRAINING AND AWARENESS ............................................................................................................................. 10

4.4.2 COMMUNICATION ....................................................................................................................................... 11

4.4.3 EMERGENCY PREPAREDNESS AND RESPONSE ............................................................................................. 11

4.5 MONITORING AND MEASUREMENT ................................................................................................................ 12

4.5.1 EVALUATION OF COMPLIANCE ................................................................................................................... 12

4.5.2 ACCIDENTS, INCIDENTS, NON-CONFORMANCE’S AND CORRECTIVE AND PREVENTIVE ACTIONS ............. 12

4.5.3 CONTROL OF RECORDS ............................................................................................................................. 13

4.5.4 HSE INTERNAL AUDIT ................................................................................................................................ 13

4.4 MANAGEMENT REVIEW .............................................................................................................................. 14

4.5 MANAGEMENT OF CHANGE .................................................................................................................. 14

4.6 APPENDIX ............................................................................................................................................. 14

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This manual describes the HSE Policy of Tech Mahindra and is designed to ensure that all the

requirements relating to HSE management system ISO 14001:2004 and OHSAS 18001:2007 are

recognized.

Purpose

With the concern to protect the Environment and maintain the Health and Safety of our Associates,

Investors, Customers and Society, Tech Mahindra has initiated a journey to be in compliance with

international standards like ISO 14001 and OHSAS 18001

Compliance to HSE (Health, Safety and Environment) at Tech Mahindra is viewed as its responsibility

for the future condition of our Environment and Health and Safety of AICS

The HSE Management System applies to operations related to Corporate Services & Human

Resources, to facilitate software project execution at HSE certified locations. This has been designed

to comply with the requirements of ISO 14001 and OHSAS 18001.

Areas covered under Corporate Services are provided below:

1) Buildings and Surroundings

2) DG

3) HT/LT Panels

4) UPS

5) Transportation

6) Transformer

7) Cafeteria

8) RO Plant

9) STP

10) TIM Server Room

11) AHU Room

12) Lifts

13) Chiller Yard

14) Housekeeping

15) Stores

16) Solid Waste yard

17) HR

Following is the list of references, which includes Standard, Manuals, plans and applicable legal

requirements and other requirements used in developing and implementing the HSE system.

2 REFERENCE

1.1 SCOPE

1 GENERAL

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ISO 14001:2004 Environmental Management Systems (Requirements with Guidance for Use)

OHSAS 18001:2007 Occupation Health and Safety Assessment Series

ISO 19011:2002 Guidelines for HSE Management Systems Auditing

ISO 14004:2004 Environmental Management Systems (General Guidelines on Principles,

System and support techniques)

Quality Policy Manual

Abbreviation / Acronym

Description

GH Group Head

AICS Associates, Investors, Customers and Society

ERT Emergency Response Team

HSE Health, Safety and Environment

IQA Integrated Quality Audit

RPN Number Risk Priority Number(Number obtained by the product of Severity, Occurrence and Detection)

TECH MAHINDRA

Tech Mahindra

MR Management Representative

SEA Significant Environmental Aspects

SEI Significant Environmental Impacts

SOA Statement of Applicability

QMS Quality Management System

NC Non Conformity

Acceptable Risk

Risk that has been controlled through meeting legal obligations, establishing and implementing appropriate control mechanisms and procedures to a level that it can be tolerated and does not offer severe hazard to health, safety and Environment

Accident Undesired event giving rise to death, ill health or injury

Audit A systematic examination to determine whether activities and related results conform to planned arrangements and whether these arrangements are implemented effectively and are suitable for archiving the organization’s policy and objectives

Continual Process of enhancing the HSE Management System, to achieve improvements in

3 DEFINITIONS AND ABBREVIATIONS

2.3 MANUALS

2.2 GUIDELINES

2.1 STANDARDS

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Improvement Environment, Occupational Health and Safety Performances ,in line with the Organization’s HSE Policy

Corrective Action

Action to eliminate the cause of a detected the non-conformity or action to reduce the severity, occurrence or improve the detection of any risk/impact

Danger A state or condition in which the personal injury is reasonably foreseeable

Emergency A serious situation or occurrence that happens unexpectedly and demands immediate action as it has the potential to seriously harm the health, safety of a group of associates or has the potential of large environmental impact.

Environment Surroundings in which the organization operates including the air, water, land, natural resources, flora, fauna, humans and their interrelation

Environmental Aspect

Element of the organization’s activities or products or services that can interact with the environment

Environmental Impact

Any change to the environment ,whether adverse or beneficial ,wholly or partially resulting from the organization’s environmental aspects

Environmental Targets

Detailed performance requirement, applicable to the organization or parts thereof, that arises from the HSE objectives and that needs to be set and met in order to achieve those objectives

Hazard Source or situation with a potential for harm and cause injury or ill health, impact the environment or a combination of these.

Health, Safety and Environment( HSE)

HSE Management System refers to policies, guidelines and practices followed by Tech Mahindra that focus on 1)Preventing harm to and promoting the health of employees and other stakeholders ;2)preventing any injuries at work both for our own employees and our contractors; and 3)protecting the environment by preventing or minimizing the environmental impact of our operations and activities.

HSE Objectives

HSE goals that are set at relevant functional areas consistent with the HSE Policy and review by the HSE Forum

HSE Performance

Measurement of the Environmental aspects and Impacts identified as part of the risk assessment and indicator of effectiveness of controls established

HSE Policy Overall intentions and directions related to Health, Safety & Environmental performance at Tech Mahindra, formally expressed by top management

Instruction Any verbal or written policy, procedure, safe system of work, code of practice or guidance relating to Health and Safety. Verbal instruction should normally be followed by in writing.

Interested Parties

Individual or groups outside Tech Mahindra concerned with or affected by the Health, Safety and Environment Management Systems performance of Tech Mahindra

Integrated Quality Audit

Systematic, independent and document process for obtaining audit evidence and evaluating it objectively to determine the extent to which the HSE Management System is complaint with the OHSAS 18001 and ISO 14001 standards

Mistake A human action that can produce an unintended result

Non Conformity (NC)

Non-fulfillment of a requirement of the ISO 14001 and OHSAS 18001 standards

Occupational Health/Health

The overall condition of body or mind; freedom from disease or abnormality

Occupational Risk

Combination of likelihood and consequence(s) of a specified event occurring which can be hazardous to Health of associates at work or in work related activities

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Significant Risk

A risk (Health, Safety and Environment) that can cause significant damage to the environment and has the potential to cause severe illness or injury

Preventive Action

Action to eliminate the cause of a potential nonconformity to HSE Policy

Qualified Worker

One who is accepted as having the necessary physical attributes and possesses the required intelligence, training and education, and has acquired the necessary skill and knowledge to carry out the work in hand to satisfy standards of safety, quantity and quality

Risk A risk is a combination of occurrence and severity of an abnormal event or failure and the consequences of that event or failure to an employee’s health, employee’s safety and the environment

Risk Acceptable

Overall process of estimating the magnitude of the risk/Impact and deciding whether or not the risk /Impact is acceptable.

Risk Control/Risk Management

Process of initiating action to eliminate or reduce the risk/Impact identified through risk assessment

Routine activities

Routine Activities which are cyclic / repetitive in nature and are part of the

regular schedule / job requirements

Non-routine activities

that are non-cyclic / adhoc in nature and are performed on need basis basis only

Normal operating condition

condition which prevails in the work area in general

i.e. unexpected / extraneous factors are not in

effect Abnormal operating condition

conditions which are not witnessed/perceived in the work place in general i.e. unprecedented s present in the work environment

BMS Business Management System

Tech Mahindra has established, implemented and maintains the HSE Management System .HSE

Management System has been designed to continuously assist in achieving the HSE objectives and

ensures compliance to legal and other requirements within the scope given. The systematic approach

to HSE promotes the efficient use of resources. Tech Mahindra commits to continually improve the

effectiveness of HSE parameters, through and inflow of observations, surveys and results into the

Risk Register.

Tech Mahindra is committed to provide healthy and safe working conditions to all its associates and is

focused on minimizing damage to the environment, wherever it operates. This will be accomplished

4.2 HSE POLICY

4.1 GENERAL REQUIREMENTS

4 HSE MANAGEMENT SYSTEM

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through training, communication & performance measurement of identified HSE parameters and there

by facilitating the continual improvement.

Tech Mahindra shall strive to conduct its business in compliance with Legal regulations & other

requirements and in line with interested party concerns. Tech Mahindra will systematically manage

the occupational risks and environmental impact(s) identified and reported.

To live up the HSE mindset, we shall work towards:

• Providing and maintaining a healthy workplace and lifestyle

• Providing and maintaining safe equipment with appropriate safety training

• Facilitating arrangements for associate safety while working

• Minimize damage to the environment and complying with legal and other requirements.

• Conducting operations to ensure efficient use of resources.

The following block diagram represents the planning function pertaining to HSE:

Tech Mahindra has established and maintains a Risk Assessment procedure that identifies potential

hazardous activities as Risk that need to be monitored for HSE compliance. The procedure

determines the significance of the Impacts and Risks identified, taking into account normal / abnormal

operating conditions or routine and non-routine activities, as applicable to Tech Mahindra.

It also ensures that the aspects/ hazards relating to these significant Impacts and Risks are

considered in setting HSE objectives. (Ref SOA for Significance Evaluation of Environmental

Aspect/Occupational health, Safety Hazards and Impacts/ Risk for details).

4.3.1 PLANNING FOR ASPECTS/HAZARDS IDENTIFICATION IMPACT/RISK ASSESSMENT AND CONTROL

4.3 PLANNING

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Risk analysis is carried out to identify the Impacts/Hazards proactively by performing risk assessment

of new activities, processes, equipment use or installations that are undertaken. Significant

Impacts/Risks are prioritized and select improvement is initiated through management programs.

Risk arising out of unsafe and/or human behavior and other human factors are identified as part of

risk assessment and are addressed through Behavior Based safety and Health program. Identifying

controls to reduce the risks will be carried out on the basis of the hierarchy of controls defined based

on the severity of the risk. In case, any such hazard originating outside the workplace, capable of

adversely affecting health and safety of associates (within TECH MAHINDRA premises) is identified,

the same would be brought to the notice of the authorities concerned to address and rectify. If the

same is not addressed within reasonable timelines, then the issue will be highlighted to the relevant

stakeholders

Tech Mahindra has established and maintains a procedure to identify and have access to legal and

other requirements which are applicable. (Ref SOA)

These legal requirement and other requirements are considered while establishing, implementing and

maintaining HSE. The Objectives and Targets are set in line with applicable legal and other

requirements.

Objectives and targets for the HSEMP’s are derived from significant environmental aspects, such as

water, power, air, noise, transport, Safety and Health.; and the views of interested parties. Objectives

and Targets are consistent with the HSE Policy and reflect our commitment to Control/Mitigate risks.

The reports are analyzed internally by the designated HSE leaders, and where required RCA is done

to ensure corrective action is planned and implemented.

The HSE Objectives and Targets are defined, documented as applicable are reviewed yearly for

continual improvement and compliance to legal and other requirements by the HSE Forum and HSE

Core Team.

Composition of HSE Forum AIC- Corporate Services, HSE Manager, Head – Maintenance, Location

Manager, Location – Maintenance Head, Location – HR and AIC – Quality

Composition of HSE Core Team: HSE Manager, Head – Maintenance, Location Manager, Location –

Maintenance Head, Location – HR, Quality Representative

Health, Safety and Environmental Management Programme(s) (HSEMP’s) are developed to achieve

the set objectives and targets for HSE. They address the delegation of responsibility to relevant

functions of the organization, detailing specific resources and timelines to complete the task and for

reviewing the programs. (Refer SOA).

The HSE Forum meets annually to review the effectiveness of the implementation of the HSE

Management system and performance against set targets. The forum can recommend suitable

changes to the HSE Management system and the objectives and targets after the review

4.3.3 HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT PROGRAMME(S)

4.3.2 LEGAL AND OTHER REQUIREMENTS

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Tech Mahindra has formed an “HSE Management Forum” with a forum head for implementation and

maintenance of the HSE Management System. The Forum determines and ensures the availability of

resources like competent personnel, proper working conditions and adequate infrastructure.

HSE Management Forum also provides timely resources to comply with legal requirement and other

requirements.

Task level responsibility to manage, perform and verify HSE work is detailed in relevant functional

procedures, including for Vendors and contract associates.

Responsibilities of HSE Forum

• To ensures the availability of resources for implementing and maintaining HSE Management

Systems.

• Review the HSE policy personnel.

• Conduct periodic performances review

• Review progress on HSE objectives and Programs

• Provide strategic guidelines to the HSE initiative

• Nominate HSE core team members and team members.

Responsibilities of HSE Core Team

• Ensure planning for HSE implementation

• Undertake periodic Risk Assessment

• Define control procedures and Implement the HSE Management programs

• Communicate significant changes, updates and other information to AICS

• Consult AICS on a periodic basis to ensure AICS involvement in HSE.

Responsibilities of HSE Manager

• To lead & facilitate implementation of Health, Safety and Environment management systems

(OHSAS 18001 and ISO 14001)

• Organizing, implementing and monitoring various HSE systems

• Facilitate communication about HSE systems to Senior Leaders and Associates.

• Undertake Incident study and root cause analysis for HSE related incidents and submit the

findings to HSE forum.

• Mentor the HSE core team in implementing HSEMS

• Review and support the Risk assessments activities.

4.4 HSE R&R

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• Identify training requirements and conduct training for HSE core team members.

Responsibilities of Group Head

• Ensure that all the resources are made available in timely manner for effective

implementation and maintaining of HSE Forum

• To ensure that HSE Policy and Procedures are followed for the HSE scoped locations

• To ensure that all the authorities and responsibilities of the associate in respective circles are

Communicated as relevant

• Ensure that appropriate communication takes place in respective circles.

• Create culture that promotes compliance, encourage associates to raise any incidents related

to HSE,

• Ensure Education, counseling and awareness programs to assist associates in practicing

sound HSE principles

Responsibilities of Associates

• Comply with HSE Policy and Procedures

• Participate in initiative in protect Environment and to reduce adverse impact on environment

• Participate in Health Initiatives, Health Check Ups and Organizational Safety initiatives

• Raise incidents if come across practices which impact on Environment or have a risk related

to Health and Safety at location

• Co-operate and participate in all the Emergency response exercises carried out at the

location

HSE Core Team member defines the competence required for performing any activity. Training needs

are identified in each function and responsibilities are assigned for carrying out trainings. Trainings will

be focused on conformance to HSE Policy, pertinent risks in respective work areas and operational

controls to be followed and potential consequences of departure from specified operating procedures.

Tech Mahindra ensures that any associate(s) performing activities are aware of the potential risks

associated with Health, Safety and Environment and are competent on basis of education and/or

training or experience to Control/Mitigate them.

The Stakeholders, i.e. AICS have a role and responsibility in meeting Tech Mahindra objectives and

targets pertaining to HSE. The HSE roles and responsibilities in minimizing adverse environmental

impacts/Occupational Health, Safety Hazards and achieving conformity with requirement of the HSE

have been defined.

4.4.1 TRAINING AND AWARENESS

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Emergency Response Team is formed to take care of the emergency arising out of Health, Safety and

Environment. The ERT Members are trained on emergency response, First Aid etc.

The effectiveness of the training is assessed by the respective Functional Leader for their function

The objective of HSE communication is to work closely with all interested parties and AICS to develop

and implement agreed HSE initiatives. At Tech Mahindra internal and external communication shall

be done effectively. All internal communication is done by the HSE core team members within the

organization. Relevant information would be shared to the external community through Annual

reports.

Participation of AICS and Interested parties is be ensured through various programs including but not

limited to the Behavior Based Safety and Health program, HSE related events, Incident reporting

procedure. HSE core team takes into account the feedbacks received as part of the consultations with

AICS and interested parties when conducting the Risk Assessment. The result of the participation and

consultations is presented to HSE Forum while considering the changes to the HSE Policy.

Significant environmental risks would be addressed internally and will not be communicated to the

external community unless there is a written communication received from any interested party, in

which case, the communication pertaining to the issue would be shared with the respective party only.

Track of all relevant incoming and outgoing communication records on interested party concerns

would be maintained

Tech Mahindra has the ability to respond promptly and appropriately to potential accidents or

emergency situations and prevent or mitigate associated adverse HSE related impact(s)/risk(s).

A documented procedure has been established, implemented and maintained to identify the potential

for, and responses to, emergency situations and potential accidents that can have an impact(s) on the

environment and health & Safety. (Ref. SOA)

Periodic mock drills are conducted to check the emergency preparedness of the team. An ERT is

formed at each floor to co-ordinate during the emergency situations/accidents.

The Emergency Preparedness and response procedure is reviewed annually and/or when standards

specification need to be revised as per the HSE standard and updated as necessary

Whenever any drills are conducted with the help of external agencies, which can be potential trigger

for panic situation in the neighborhood, nearby companies are kept informed on the same, to avoid

any type of panic at their end. For other types of mock drills, which are conducted internally, no

proactive communication is sent to external entities.

4.4.3 EMERGENCY PREPAREDNESS AND RESPONSE

4.4.2 COMMUNICATION

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We monitor on a daily/monthly basis the activities defined in the Risk assessment register. Basis the

RPN we prioritize and re-review the parameters and revise/re-test the targets and objective

measures..

HSE Management Programs are monitored as per the schedule prepared and measured for

performance. Guidelines of HSEMP are used in conjunction with internal inspections and audits to

monitor relevant operation controls, track compliance with legal and other HSE requirements and

record associated information. (Ref. Quality Policy Manual)

Tech Mahindra has established the Periodical evaluation and compliance with relevant environmental/

Occupational Health, Safety legislation and regulations and other requirements and are documented.

(Ref. SOA)

Tech Mahindra has established and maintains a procedure to identify and to have access to legal and

other requirements that are applicable to the environmental aspects and occupational health and

safety of the activities, products, equipment’s or services. Legal and other requirements are identified

and updated through regular interactions with concerned authorities and/or by subscribing to the

Central and State Government gazettes and Cll. Copies of the updated legal and other requirements

and a Register of these requirements are maintained in the Legal register.

Tech Mahindra has established and maintains procedures, and defined responsibility and authority,

for handling and investigating non conformance, taking action to mitigate any impacts caused and for

initiating and completing corrective and preventive actions.

These procedures make provisions for taking corrective or preventive actions as necessary to

eliminate the causes of actual and potential non conformance’s to the degree appropriate to the

magnitude of the problems and commensurate with the environmental impact encountered.

Tech Mahindra implements and record changes in the documented procedure resulting from

corrective and preventive action

Procedures for corrective action include:

a) The effective handling of HSE related complaints and nonconformities;

b) Investigation of the root cause of non conformities relating to accidents, incidents, property

damage, permit excursions, spills, beneficial occupancy inspections, annual inspections,

external audits, associate concerns/ near misses, complaints and trends identified

by the management review process

c) Determination of the corrective action needed to eliminate the cause of nonconformity

d) Application of controls to ensure that the corrective action is taken and that it is effective;

e) Classification of non-conformities based on severity to ensure the corrective actions is

4.5.2 ACCIDENTS, INCIDENTS, NON-CONFORMANCE’S AND CORRECTIVE AND PREVENTIVE ACTIONS

4.5.1 EVALUATION OF COMPLIANCE

4.5 MONITORING AND MEASUREMENT

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commensurate with the impact to the associates, facility, public and environment

Procedures for preventive action include;

a) The use of appropriate sources of information as needed to detect, analyze and eliminate

potential causes of non-conformities.

e) The proposed corrective actions are reviewed through the risk assessment prior to the

Implementation.

Post the successful implementation of the corrective action, the steps are standardized in the relevant

operational control procedure to ensure prevention.

Associated non-conformance and corrective and preventive action records are maintained. (Ref.

SOA)

Tech Mahindra maintains records of the results achieved to demonstrate conformity to the

requirements of the HSE Management System. These are maintained in legible, identifiable and

traceable form with the respective stakeholders.

Identification and maintenance of records are as per Quality Policy Manual. The records include

• Training Records,

• Inspection, maintenance and calibration records if any

• Incident Reports,

• Record of tests for emergency preparedness,

• Audit results,

• Management view results,

• External Communications,

• Records of applicable legal and other requirements,

• Records of significant environmental aspects/hazards related to health and safety,

• Environmental performance information,

• Legal compliance records, and

• Communications with interested parties if any.

Internal Quality Audits are carried out bi-annually, to ensure that HSE compliance as required by

ISO14001 and OHSAS18001. The Controls are verified to ensure HSE activities and related results

comply with the Objectives and targets in the risk assessment register.

4.5.4 HSE INTERNAL AUDIT

4.5.3 CONTROL OF RECORDS

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A detailed IQA procedure is established and maintained. The IQA’s are carried out as per Annual

Audit plan. IQA training is conducted to qualify the Internal Quality Auditors. Trained and qualified

internal auditors independent of the function being audited, conduct audits

The audits findings are logged for tracking and corrective action.

The senior management reviews the HSE Management System, review its continuity, suitability,

adequacy and effectiveness. The management review process involves the dissemination of

information from the annual HSE Forum meeting. The management review addresses the possible

need for changes to the policy, objectives and elements of the HSE Management System Agenda for

HSE Forum Meeting:

a) HSE @ TECH MAHINDRA

b) Results of Internal Audits. Corrective and Preventive Actions

c) Communication from external interested parties, including complaints

d) HSE performance

e) Objectives and targets

f) Action items from previous management reviews

g) Changing circumstances, legal and other requirements

h) Recommendations and improvement (including changes)

i) BBSH Data Analysis

j) Results of participation and consultation

k) Incident Investigations, corrective & preventive actions

Tech Mahindra re-assesses HSE and other Risks when planned or unplanned changes occur. The

HSE forum and core team comprises of associates trained on the HSE standard to ensure

correctness and completeness and requirements of the standard is maintained.

Statement of Applicability

ISO 14001:2004 OSHAS 18001:2007

References Documents/ Records Clause Particulars

Clause

Particulars

1 Scope 1 Scope HSE Manual HSE Manual

2 Normative references

2 Reference publication

HSE Manual HSE Manual

4.6 APPENDIX

4.5 MANAGEMENT OF CHANGE

4.4 MANAGEMENT REVIEW

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3

Terms and definitions

3

Terms and definitions

HSE Manual

HSE Manual, Respective Procedures

4

Environmental management system requirements

4

OH&S management system elements

4.1 General requirements

4.1 General requirements

HSE Manual

4.2 Environmental policy

4.2 OH&S policy Quality Policy manual; HSE Manual

HSE Manual

4.3 Planning 4.3 Planning 4.3.1

Environmental aspects

4.3.1

Planning for hazard identification, risk assessment and risk control

HSE Risk Management Procedure

Risk Assessment sheet

4.3.2

Legal and other requirements

4.3.2

Legal and other requirements

HSE Manual; Risk Assessment procedure, Procedure for identification of Legal & Other Requirements

Legal Register

4.3.3

Objectives, targets and programme(s)

4.3.3

Objectives

1. HSE Manual. 2. HSE Risk Management Procedure 3. Procedure for HSE M Programs

1. HSE Management Programs planned and conducted 2. Six Sigma Projects Ongoing and closed (Records of the same)

4.3.4

OH&S Management programme (s)

1. HSE Manual. 2. HSE Risk Management Procedure 3. Procedure for HSE M Programs

1. HSE Management Programs planned and conducted 2. Six Sigma Projects Ongoing and closed (Records of the same)

4.4 Implementation and operation

4.4 Implementation and operation

4.4.1

Resources, roles, responsibility and authority

4.4.1

Structure and responsibility

HSE Manual; Quality Policy Manual

Procedural documents for respective areas

4.4.2

Competence, training and awareness

4.4.2

Training, awareness and competence

Quality Policy manual; HSE Manual; SLC Processes - Induction and QMS Training Respective Procedures

1. Records of HSE trainings done 2. Calendar of training planned

4.4.3

Communication

4.4.3

Consultation and communication

HSE Manual Internal & External Communication Procedure

1. Records of various communications

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4.4.4

Documentation

4.4.4

Documentation

1. DG and its distribution Systems 2. UPS and its distribution Systems 3. AC and its distribution Systems 4. Waste Management Procedure 5. Cafeteria Management Procedure 6. Transport Management Procedure

Records and evidences for the list mentioned in the previous column (E20)

7. Incident Management Procedure

4.4.5 Control of documents

4.4.5 Document and Data control

HSE Manual; Document and Data control

BMS

4.4.6

Operational control

4.4.6

Operational control

HSE Risk Management Procedure - Noise pollution Procedure - Soil pollution Operational Control procedure for Transport

Risk Management Checklist

4.4.7

Emergency preparedness and response

4.4.7

Emergency preparedness and response

1. ERT Procedure 2. Guidelines for First Aid

1. Records of ERT drills carried out 2. Reports of Incidents happened

4.5

Checking

4.5

Checking and corrective action

4.5.1

Monitoring and measurement

4.5.1

Performance measurement and monitoring

Quality Policy Manual; HSE Manual, Individual Procedures for key performance measures

1. QMR's 2. IQA 3. Periodic Risk Assessment

4.5.2

Evaluation of compliance

4.5.2

Accidents, incidents, non- conformances and corrective and preventive action

HSE Manual; Corrective and preventive action procedure

IQA

4.5.2.1

Evaluate compliance with applicable legal requirements periodically

Legal Compliance Procedure

4.5.2.2

Evaluate compliance to other subscribed requirements

4.5.3

Nonconformity, corrective action and preventive action

Corrective and Preventive Action Procedure

4.5.4

Control of records

4.5.3

Records and records management

Document And Data Control Procedure

BMS

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HSE Policy Manual Company-Confidential

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4.5.5 Internal audit 4.5.4 Audit Internal quality audits procedure

4.6

Management Review

4.6

Management review

Management Review procedure

MOMs of the review with tracking