zc cop ehs11 audits & inspections

8/12/2019 ZC COP EHS11 Audits & Inspections

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Higher orporation for Specialized Economic Zones HIGHER ORPOR TION FOR IPE I LIZED E ONOMI ZONES

ODE OF PR TI E GUIDELINES ONEHS UDIT ND INSPE TIONZones orp COP EHS

APPROVED BY: DATE:


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CODE OF PRACTICE GUIDELINES

EHS AUDIT AND INSPECTION

Document No ZC-COP-EHS11 Rev. No. 0 Date of Issue 21 Sept. 2008

Industrial Sector Environment Health & Safety Regulatory Framework Page 2 of 70

REVISION HISTORY

Rev. No. Issue Date Revised Section Revision Description

0 New Documents

Copyright

The copyright and all other rights of a like nature in this document are vested in Higher Corporation forSpecialized Economic Zones (ZonesCorp), Abu Dhabi, United Arab Emirates. This document isissued as part of the Industrial Sector EHS Regulatory Framework and as guidance to IndustrialSector within the Abu Dhabi Emirates. Any party within Industrial Sector may give copies of the entireEHS Documents or selected parts thereof to their contractors/consultants for implementation of EHSManagement Standards. Such copies should carry a statement that they are reproduced bypermission of ZonesCorp and an explanatory note on the manner in which the document is to beused.

Disclaimer

No liability whatsoever in contract, tort or otherwise is accepted by ZonesCorp or any party whether ornot involved in the preparation of the EHS Management System Documents for any consequenceswhatsoever resulting directly or indirectly from reliance on or from the use of the ZonesCorp EHSDocuments or for any error or omission therein even if such error or omission is caused by a failure toexercise reasonable care.

All administrative queries should be directed to the ZonesCorp EHSMS Administrator HSE Division

Higher Corporation for Specialized Economic ZonesP.O. Box: 36000, Abu Dhabi,United Arab Emirates.

Telephone: (9712) 5073358Fax: (9712) 5073564Internet site: www.zonescorp.comE-mail: [email protected]


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TABLE OF CONTENTS

1. PURPOSE 4

2. SCOPE 5

3. DEFINITIONS 6

4. EXISTING APPLICABLE LAWS 9

5 RESPONSIBILITIES 11

6. EHS AUDITS 13

7 AUDIT CATEGORIES 148 EHS MANAGEMENT SYSTEM AUDITING 15

9 EHS AUDIT TEAM 16

10 KEY STEPS FOR EHS AUDIT 18

11 SCOPE OF EHS AUDITING 19

12 EHS AUDIT PLANNING 21

13 MANAGING THE AUDIT PROGRAM 22

14 CONDUCTING THE AUDIT 24

15 EHS MANAGEMENT SYSTEM AUDIT COMPLIANCE SCORE 26

16 DOCUMENTING THE AUDIT FINDINGS 27

17 AUDIT REPORTS 29

18 EHS INSPECTIONS 30

19 EHS INSPECTION PROGRAM 31

20 REFERENCES 35

21 APPENDIX 1 INDUSTRIAL SECTOR EHS COMMITMENT & POLICY 36

22 APPENDIX 2 LIST OF EHS CODES OF PRACTICE 3723 APPENDIX 3 EHS MS AUDIT BASIC REQUIREMENTS 39

24 APPENDIX 4: EHS AUDIT CONCERNS 58

25 EHS AUDIT CHECKLIST RECOMMENDED FORMAT 62

26 BUILDING EHS AUDIT CHECKLIST RECOMMENDED FORMAT 64

27 EHS INSPECTION CHECKLIST RECOMMENDED FORMAT 70


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1. PURPOSE

This document establishes the ZonesCorp Regulatory Requirements andprovides guidelines to establish the basic framework and generalrequirements for conducting EHS Audits & Inspections.

Industrial Sector Entities may develop their own procedure appropriate to theirorganisations activities to meet or exceed the requirements stipulated in thisCode of Practice.

Environment Agency Abu Dhabi (EAD) being the Competent Authority ofEHS Management within Abu Dhabi Emirate has designated Higher

Corporation for Specialized Economic Zones ZonesCorp as the EHSRegulatory Authority for the Industrial Sector within Abu Dhabi Emirate.ZonesCorp in its Regulatory Role is the nodal agency for the Entities withinIndustrial Sector while interacting with concerned Govt. Agencies (EAD, CivilDefense etc.) for fulfilling the applicable regulatory requirements like EHSPermitting etc.

The Higher Corporation for Specialized Economic Zones ZonesCorp beingthe EHS Regulatory Authority for the Industrial Sector in the Emirate of AbuDhabi, has established the Environmental, Health & Safety RegulatoryFramework Codes of Practice to communicate the requirements of EHSmanagement as a key factor in successful business development to allindustries within the Emirate of Abu Dhabi. ZonesCorp considers theestablishment of priorities, programmes and practices as vital for integratinggood environmental, health & safety management into all entities business.

The Industrial Sector EHS Regulatory Framework has been established in linewith the requirements of UAE EHS Laws, Regulations and the Abu Dhabi(EAD) EHS Management System Framework Documents for the IndustrialSector. The system is also aligned with other international standards likeISO14001, OHSAS18001 and BS8800 for Occupational Health.

The document is not addressing the requirements for monitoring for Integrity

Assurance of Equipment / Systems / Structures which are separately coveredin ZonesCorp Code of Practice on Integrity Assurance & Management (ZC-CoP-EHS10). Any section / clause of this document shall therefore notsubstitute any requirement of the above referred CoP.


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2. SCOPE

The requirements outlined in this document are applicable to EHSManagement System Audit, EHS Audit & Inspection activities carried out in allOperating Facilities, Buildings and Construction Worksites.

This document is applicable to all Entities within Industrial Sector in AbuDhabi Emirate.

The Industrial Sector includes but is not limited to Entities in Abu DhabiIndustrial Cities (ICADs), Al-Ain Industrial Cities (AAICs), Western RegionIndustrial Complex, Mussafah Industrial Area and Workers Facilities (Labour

Camps) for Industrial Sector within Abu Dhabi Emirate.Wherever possible, and rather than providing detail within this document,reference is made to other, more detailed documents that have been providedin the ZonesCorp EHS Management System.


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3. DEFINITIONS

3.1 Asset: Any person, environment, facility, material, information, businessreputation or activity that has a positive value to an owner.

3.2 Audit: An audit is a systematic, independent, and documented process forobtaining evidence and evaluating it objectively to determine the extent towhich the audit criteria are fulfilled (ISO 19011:2003). Qualified professionalswith relevant auditing experience can conduct most audits and wherepossible, independent external auditors should also be used.

3.3 EAD: Environmental Agency Abu Dhabi. Competent Authority for EHS

Management System in Emirate of Abu Dhabi3.4 EEPP: Abu Dhabi Emirate Environment Protection Policy

3.5 EHS: Environment Health & Safety

3.6 EHS MS: EHS Management System.

3.7 EHS Audit

3.7.1 EHS audit is a systematic review of operations and practices to ensure thatrelevant requirements are met. These are planned evaluations onperformance and compliance.

3.7.2 It is a structured, methodical assessment and evaluation of how workplaceactivities affect Safety Health, and Environment. It reveals how anorganization is doing in maintaining a safe and healthy environment.

3.7.3 The basic goal of EHS audit is to verify that EHS activities comply withorganization policies and regulations.

3.7.4 This also covers the EHS-Management System Audit - An audit to verifycompliance with ZonesCorp and/or Tenant(s) EHS Management Systemrequirements and expectations

3.7.5 An independent, systematic and documented process of objectively obtainingand evaluating verifiable evidence to determine that business controls:

a. Are complete and consistent.

b. Are (cost) effective and efficient.

c. Safeguard organizations resources and promote their effective use.

d. Provide, and protect the integrity of, required records and information.

e. Allow for compliance with policies, chosen standards, laws and regulations

3.8 EHS Audit Team

3.8.1 Team structure shall be linked with the location/facility to be audited.


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3.8.2 Facility / Location specific Audit Team shall be nominated by concerned

Management in consultation with HSE Manager or equivalent.3.8.3 In general audit shall comprise of members at least one each from HSE,

Operations, Maintenance, Engineering & Projects, Divisions/Departments inBuildings, Contractors Representatives (for construction sites)

3.8.4 HSE representative shall be audit coordinator.

3.8.5 Team leader shall at least be Department Manger / Section Head nominatedon rotation basis. Team leader shall not be responsible for the area to beaudited

3.9 EHS Audit Reports: Report based upon the audit findings (checklist)

normally presented in a format indicating the salient observations, actionsrequired, responsibilities, recommendation and target dates.

3.10 EHS Inspections

3.10.1 EHS Inspections are the walk-through of the physical areas of the facility,with the goal of identifying EHS hazards & concerns.

3.10.2 A scheduled, structured examination of a worksite with a specific focus onphysical conditions & working practices in addition to normal supervisory duties

3.10.3 The surveys shall be conducted on a regular frequency by the inspectionteam including the representative from the area to be inspected.

3.10.4 Inspection team members are to note problem areas, write reports, presentthe report to concerned, offer recommendations, set completion dates andfollow-up to ensure action has taken place.

3.10.5 Inspections should concentrate on working conditions, working practices,housekeeping, process controls, hazard exposure, and other similarconcerns.

3.11 Emergency: A sudden and usually unforeseen event that requires immediateaction to minimize its consequence

3.12 Entity: Facilities within Industrial Sector including Industrial, Commercial,Residential and Welfare

3.13 Hazard: Any substance, physical effect, or condition with potential to harmpeople, property or the environment or affect on the company reputation

3.14 Incident: An uncontrolled / unplanned/undesired / uncontrolled event thatresults in undesirable consequences to the personnel (injuries/illness) and / orto the assets (damage/loss) or to the neighbouring community and/or to theenvironment. The term Incident is synonymous with Accident wherever usedin ZonesCorp EHS Management Framework

3.15 Industrial Sector: Industrial Sector within Abu Dhabi Emirate includes but notlimited to Entities (Industrial Units etc.) in Industrial Cities developed by

ZonesCorp, Industrial Areas like Mussafah, Mafraq, etc. and Workers


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4. EXISTING APPLICABLE LAWS

All Tenants shall ensure that their operations comply with all relevant UAEand Abu Dhabi Environmental, Health and Safety laws and regulations.Environmental, Health and Safety regulations in the UAE are gradually beingimplemented.

This Code of Practice has been developed to ensure compliance to or exceedthe requirements of all relevant legislative statutes and regulations,specifically including but not limited to:

4.1 Federal EHS Laws and Codes including UAE Standards Industrial Safety &

Health Regulations (Emirates Authority for Standardization & Metrology)4.2 Local Law No. ( ) of 2008 concerning Environment Health & Safety

Management System in Abu Dhabi Emirate

4.3 Local Law No. 16 of 2005; Article 14 Establishment or Individual is prohibitedto carry out any activity that could adversely affect the lives of human beingsand the safety of the environment before obtaining a license from the Agency.

4.4 Local Law No. 21 of 2005 on the Waste Management in Emirate of Abu Dhabi

4.5 Local Law No. 23 of 2005 and the Executive Regulations Regarding theHealth Insurance Scheme for the Emirate of Abu Dhabi

4.6 Federal Law No. 1 of 2002 Regarding Organisation & Monitoring the Use ofRadiation Resources and Protection

4.7 Federal Law No. 8 of 1980. The Labor Law (as amended 1986)

4.8 Federal Law No. 23 of 1999 Marine Bio-Resources in the UAE

4.9 Federal Law No. 24 of 1999 for the Protection & Development of theEnvironment

4.10 Regulations / Executive Ordersmade under the Federal Environment Law

a. Federal Bylaw; Protection of Air from Pollution (Ministerial Order # 12 of

2006)b. Federal Bylaw; System for Protected Area

Ministerial Decree No. 37 of 2001 concerning the approval of the ExecutiveOrders for Law No. 24. It includes the following Regulations:

a. Environmental Impact assessment of Projects 2001

b. Assessment of Environmental Effects of Installations 2001

c. Protection of the Marine Environment 2001

d. Handling Hazardous Materials, Hazardous Wastes & Medical Wastes 2001

e. Pesticides, Agricultural Additives and Fertilizers 2001


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4.11 Ministerial Decrees & Decisions:

a. Decree No. 50/2003 Basic Regulating Rules for Ionizing RadiationProtection

b. Decree No. 55/2004 Basic Regulations for Protection against IonizingRadiation.

c. Decree No. 56/2004 Basic Regulations for Safe Transport of RadioactiveMaterials

d. Decree No. 57/2004 Basic Regulations for Radioactive Waste Management

e. Decree No. 214/2004 on Use of Sludge on Land

f. Ministerial Order No.32/1982 on the Determination of Preventative

Methods and Measures for the Protection of Labor from Risks at Work4.12 Abu Dhabi Emirate Environment Protection Policies (EEPPs)

a. Part 1 Air Quality

b. Part 2 Water Quality

c. Part 3 Land Quality

d. Part 4 Noise

e. Part 5 Waste

f. Part 6 Hazardous Substances

g. Part 7 Occupational and Environmental Health & Safety

h. Part 8 Biodiversity and Conservation

4.13 Abu Dhabi Emirate Environment Protection Policies Standards

a. Part 1 Air Quality Standard

b. Part 2 Water Quality Standard

c. Part 3 Land Quality Standard

d. Part 4 Noise Quality Standard

4.14 Abu Dhabi Emirate EHS Management System Codes of Practices

a. Self Regulation

b. Roles & Responsibilities

c. Risk Management

d. Audits & Inspection

e. Emergency Management

f. Monitoring and Reporting

g. Management Reviews

4.15 EAD Regulations on Hazardous Material & Waste Permit

4.16 Industrial Safety and Health Regulations Occupational Health and

Environmental Control SSUAE No. 209 / 1995.


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5. RESPONSIBILITIES

5.1 Competent Authority

The Competent Authority (EAD) in cooperation with the Regulatory Authority(ZonesCorp) shall approve the types of entities (targeted entities) that shoulddevelop & implement an EHSMS in accordance with the Abu Dhabi EmirateEHS Law.

The Competent Authority (EAD) shall set mechanisms for:

Reviewing and approving EHSMS developed by Entities to ensurecompliance with the requirements of the EHSMS at Abu Dhabi Emiratelevel.

Auditing the EHSMS implemented by different entities.

The Competent Authority (EAD) shall promote the importance ofimplementing the EHSMS.

The Competent Authority (EAD) shall be responsible for reporting to theExecutive Council the performance of the EHSMS at Abu Dhabi Emirate level.

5.2 Regulatory Authority

The Regulatory Authority (ZonesCorp) in cooperation with the Competent

Authority (EAD) shall identify the types of entities that should develop &implement an EHSMS in accordance with the Abu Dhabi Emirate EHS Law.

The Regulatory Authority (ZonesCorp) in cooperation with the CompetentAuthority (EAD) shall implement mechanisms for:

Reviewing and approving EHSMS developed by entities in compliance tothe requirements of the Abu Dhabi Emirate EHSMS.

Auditing the EHSMS implemented by different entities.

Receiving EHSMS Performance from Industrial Sector Entities

Compilation and reporting EHSMS Performance of Industrial Sector to the

Competent Authority (EAD)

The Regulatory Authority (ZonesCorp) in cooperation with the CompetentAuthority (EAD) shall promote the importance of implementing the EHSMS.

5.3 Entities

5.3.1 Entities shall provide and maintain a safe environment for workers, avoid anyrisk to human health, avoid adverse impact to environment and preventenvironmental pollution.

5.3.2 Entities shall develop and implement an EHSMS within their areas ofjurisdiction to protect their employees, the community and the environment

from any adverse impacts arising from their activities.


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5.3.3 Entities having an EHSMS are required to audit their System in order to

ensure conformance with ZonesCorp EHSMS Requirements.5.3.4 Entities having established an EHSMS are required to demonstrate self

regulation

5.3.5 Entities having an EHSMS are required to submit an annual report to theZonesCorp / EAD on the performance of their System as per the mechanismset by ZonesCorp.

5.4 Employers Duties

5.4.1 Employers have the ultimate responsibility to ensure the health and safety oftheir employees.

5.4.2 Employers have a general Duty of Care to take all practicable steps to ensurethe safety of their employees while at work, visitors and contractors.

In particular, they are required to take all practicable steps to:

Provide and maintain a Safe Working Environment;

Provide and maintain facilities for the Safety and Health of employees atwork;

Ensure that machinery and equipment are safe;

Ensure that working arrangements are not hazardous to employees; and

Ensure a Safe System of Work comprising at least of Procedure, Training,Communication & Supervision is in place

Ensure procedures are available to deal with emergencies that may arisewhile employees are at work.


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6. EHS AUDIT

6.1 The purpose of EHS Audit is to ensure compliance to EHS ManagementSystem, Procedures and a safe and healthy workplace by striving to eliminateunsafe practices and hazards that lead to injuries and accidents.

6.2 EHS Audits are report cards on the success of EHS programs. Like financialaudits, EHS audits are structured evaluations on performance & compliance.

6.3 EHS Audit is a structured, methodical assessment and evaluation of howworkplace activities affect safety, environment and health. It reveals how anorganization is doing in maintaining a safe and healthy environment. Its goal

is to ensure a safe and healthy workplace by striving to eliminate unsafepractices and hazards that lead to injuries and accidents.

6.4 An audit consists of two parts: gathering data about a program and evaluatingthe data. The audited program must comply with a variety of regulations andguidelines: federal environmental, safety, and health regulations; local andstate requirements; and internal institutional performance requirements.

6.5 An audit should identify the strengths as well as the weaknesses of aprogram. It should reveal to management and the employees where and howthey could and should make improvements.

6.6 On-site Audits require three main actions.6.6.1 First, arrange interviews with facility personnel who have key roles in

developing or implementing safety management systems.

6.6.2 Next, review documentation that defines safety system records or verifiescompletion of critical tasks. These tasks may include emergencypreparedness; hazard identification, control, and monitoring; and safetyeducation and training.

6.6.3 Last, conduct field assessment of the facility or equipment. Here, theassessment might include verification of implementation of safety practices.For example, are only certified welders performing hot work (welding)? Does

he have hot work permits?

6.7 Audit data, obtained by reviewing written records and procedures,interviewing personnel, and personal observation, are collected from both anadministrative area and a management or operational area, which controls thephysical environment.

6.8 Audit of the administrative area includes a review of how well or how poorlymanagement has implemented the program. Audit of the operational areas,whereby management controls the physical environment, includes assessingthe surroundings and external conditions that influence the daily operation ofthe organization.


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7 AUDIT CATEGORIES

7.1 Level 1 Audit: To be conducted at Corporate level (for the wholeorganization) by Internal or External Auditors.

7.2 Level 2 Audit:To be conducted at Divisions Level within the Organization byInternal Auditors.

7.3 Level 3 Audit:or Inspections. to assess at the Sections/Department level, thephysical conditions of the workplace and to physically verify that operationsare conducted in accordance with EHS Policy, Standards and Procedures.

Note 1: Depending upon the organizational structure and size the appropriate

category of audit (Level 2 or 3) should be selected.

Note 2:Where applicable Contractors Worksites shall be covered in all theAudits

7.4 External Audits

7.4.1 External audits can be carried out for all audit levels. These audits shall be inaddition to Internal Audits

7.4.2 Entities shall ensure external audits being conducted by EAD/ZonesCorpapproved auditors on annual basis. The report shall be submitted toZonesCorp as a part of EHS Performance monitoring. Refer to ZonesCorp

Code of Practice on EHS Performance Monitoring & Reporting ZC-CoP-EHS06

7.4.3 ZonesCorp shall conduct an audit of Entitys EHS Management System atapproximately three yearly intervals.

7.4.4 The ZonesCorp EHSMS audit aims to verify Entitys implementation of, andcompliance with the ZonesCorp EHS MS requirements and expectations.

7.4.5 Consultants, ISO 14001 certification bodies, etc., may also perform externalEHS audits.

7.4.6 External audits shall be tracked and followed up similarly to internal audits,

with same responsibilities.

7.5 Self Assessments

7.5.1 Entities shall perform an EHS MS self assessment on an annual basis or afrequency set by the concerned Management. This shall be performedaccording to the requirements as outlined in this document

7.5.2 Entitys Management shall co-ordinate and support the EHS MS selfassessment process in order to ensure objectivity and consistency ofapproach.

7.5.3 The EHS MS self assessment may be submitted as part of the EHS

Performance Reporting.


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8 EHS MANAGEMENT SYSTEM AUDITING

8.1 The EHSMS auditing, for the purposes of implementing the objectives,principles and intent of the EHSMS Framework, should include (whererelevant), but not be limited to the following areas:

a. EHS Management Systems;

b. Discharges to air, water and land;

c. Management of water (wastewater, groundwater, drinking water);

d. Minimization and management of waste including resource recovery,

reuse and recycling;e. Hazardous waste management and responding accordingly to

hazardous releases;

f. Managing hazardous substances such as asbestos, pesticides & oilpollution;

g. Noise management;

h. Occupational and public health and safety (includes workers andvisitors, customers and neighbors) including personal protectiveequipment and training and supervision;

i. Adequacy of monitoring and measurement practices (includingcalibration);

j. Aboveground and underground storage tank management;

k. Risk assessment and management including hazard identification andcommunication; and

l. Emergency management planning and response.

8.2 This document is however limited to the EHS Management System Audit, theauditing requirements for other above listed items are addressed in therelevant Code of Practices

8.3 EHS Management System Audits aims to verify compliance with EHSManagement Systems Elements and associated Expectations. Refer toZonesCorp Code of Practice on EHS Management System ZC-COP-EHS02

8.4 The EHS MS Audit program should be designed, developed and implementedin accordance with, ZonesCorp EHS MS requirements and the applicableinternational standards like ISO:


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9 EHS AUDIT TEAM

9.1 EHS Audit team should comprise a lead auditor, an engineer (or equivalent)familiar with the area/plant/equipment and/or process, and a person withexperience in the relevant field, e.g. EHS.

9.2 During operations, each Manager is responsible for controlling the regularfrequency of audits for its facility or area of management. Line Managersmust be satisfied that appropriate due diligence is being achieved.

9.3 EHS Audit Team shall be nominated by concerned Management inconsultation with HSE Manager or equivalent.

9.4 The recommended members of the team shall be as defined in section 3. Ingeneral audit shall comprise of members at least one each from HSE,Operations, Maintenance, Engineering & Projects, Divisions/Departments inBuildings, Contractors Representatives (for construction sites).

9.5 EHS Audit Team leader shall at least be a Department Manager / SectionHead or equivalent nominated on rotation basis. Team leader shall not beresponsible for the area to be audited.

9.6 HSE representative shall be the EHS Audit coordinator and an essentialmember of the audit team.

9.7 EHS Auditors must be suitably knowledgeable, experienced and qualified toundertake EHS audits. Refer to the preceding sub-sections.

9.8 Audit Team Responsibilities

9.8.1 EHS Auditors, and their Audit Team, have a primary duty of care to theEnvironment, Health and Safety and above all to the organization. They haveethical as well as technical obligations in the fulfillment of their duties.

9.8.2 Ethically, EHS Auditors are obliged to:

a. Provide true and accurate information concerning their investigations;

b. Not issue inaccurate EHS audit reports, or conceal relevant information

from the concerned management, ZonesCorp, EAD etc.; and

c. Notify ZonesCorp / EAD of any imminent hazard to workers, thecommunity or the environment, or fraudulent activity, as soon aspracticably possible during the course of conducting the EHS audit

9.8.3 Technically, EHS Auditors are obliged to:

a. Refer to documents (CoP, Guidelines etc.) developed by the ZonesCorp,EAD and updated international standards in the course of conducting theaudit;

b. Utilise best practice methods while conducting assessments;


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c. Exercise due care, diligence, and professional judgement while conducting

their activities to a standard expected of a qualified environmental, healthand safety auditor;

d. Conduct audit only in areas within their competence; and

e. Ensure that EHS audit statements or reports are based on soundobservations and logical deductions and analysis.

9.9 Types of EHSMS Auditors

a. The following types of EHSMS auditors are required for theimplementation of the objectives, principles and intent of the EHSMSFramework:

b. EHS Management System Auditors;

c. EHS Industrial Facilities Auditors;

d. EHS Contaminated Land Auditors;

e. EHS Hazardous Materials Auditors;

f. EHS Occupational Hygiene Auditors;

g. EHS Monitoring Measurement Auditors; and

h. EHS Air Quality Modelling Auditors;

9.10 Qualifications for EHSMS Auditing Personnela. Internal EHSMS auditors must be suitably knowledgeable, experienced

and qualified to undertake EHS audits.

b. External EHSMS auditors must be suitably knowledgeable, experiencedand qualified to undertake EHSMS audits.

c. The training undertaken by external EHSMS Auditors must be recognizedand sufficient to be certified to undertake EHSMS audits of managementsystems in accordance with the standards prescribed in Section 13, orrecognized equivalent.

d. Only ISO certified auditors, or an equivalent recognized by the ZonesCorp/ EAD, should conduct external EHSMS audits in accordance with thispolicy.


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10 KEY STEPS FOR AUDITING

10.1 The figure presented below contains guidelines on planning and conductingaudit activities as part of the audit program. The extent to which the provisionsof these guidelines are applicable depends on the scope and complexity ofthe specific audit and the intended use of the audit conclusions.

Initiating the audit

1. Appointing the Audit Team Leader2. Defining audit objective, scope, and

criteria3. Determining the feasibility of the audit4. Selecting the audit team5. Establishing initial contact with the

auditee

Conducting document review

6. Reviewing relevant EHS ManagementSystem documents including recordsand determining their adequacy withrespect to audit criteria

Preparing for on-site audit activities

7. Preparing the audit plan8. Assigning work to the audit team9. Preparing work documents

Conducting on-site audit activities

10. Conducting opening meeting11. Communication during the audit12. Roles and responsibilities of guides and

observers13. Collecting and verifying information14. Generating audit f indings15. Preparing audit conclusions16. Conducting closing meeting


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11 SCOPE OF EHS AUDITING

11.1 The scope of EHS auditing, for the purposes of implementing the objectives,principles and intent of the organizations EHS objectives, should include(where relevant), but not be limited to the following areas:

a. EHS Management System including EHS Control Procedures

b. All existing written EHS programs

c. Compliance to Safe Work Procedures and Practices

11.2 Appendix 3 & 4presents a set of basic requirements recommended for use

in EHS MS and EHS Audits and Self Assessments. This is based upon theEight Elements of ZonesCorp EHS MS and the associated expectations

11.3 In addition to the EHS Policy Statement and Commitment (Appendix 1),thereare EHS expectations that are contained within 8 Elements of ZonesCorpEHS Management System (CoPEHS02). Together, these 8 Elementsprovide a framework for managing EHS. List of existing Code of Practicesincluded in ZonesCorp EHS Management System is provided in Appendix 2

The 8 EHS Elementsare listed below and EHSMS Audit should consider theassociated expectations. The Elements are:

a. Element 1 Leadership and Commitment

b. Element 2 Policy and Strategic Objectives

c. Element 3 Organization, Resources & Competency

d. Element 4 Risk Evaluation & Management

e. Element 5 Planning, Standards and Procedures

f. Element 6 Implementation and Performance Monitoring

g. Element 7 Compliance Assurance (Audits/Inspections)

h. Element 8 Management Review

In addition, the following environmental principles are to be upheld:a. Full compliance with all EAD standards as a minimum

b. Full compliance to Abu Dhabi Emirate Environmental ProtectionPolicies (EEPPs) and Standards

c. Minimization of power requirements.

d. No unplanned venting of gases from process facilities.

e. Utilization of best available technology to minimize fugitive emissions.

f. No utilization of ozone depleting substances.

g. No discharge of off-spec water to land or sea.


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h. No discharges of oil or chemicals to land or sea

i. Minimization of waste generation.

j. Optimization of facilities footprint to reduce environmental impacts.

k. Minimization of visible impacts, noise and odour

11.4 Areas of consideration shall at least include:

a. EHS MS Expectations

b. EHS Control Procedures

c. Engineering Controls

d. Administrative Controls (Procedure, Work Instructions etc.).e. Personal Protective and Safety equipment.

f. Periodic Inspections Records and status of action items.

g. Employee Training Records and needs

h. Site Compliance Deficiencies.

i. Unsafe Conditions / Unsafe Acts

j. Spills / Leaks

k. Adequacy of monitoring & measurement practices (including calibration);

l. Managing hazardous substances such as asbestos, pesticides and oilpollution;

11.5 Appendix 3presents the EHS MS Audit Basic Requirements and Appendix4presents EHS Audit concerns

11.6 Environment maters like hazardous material & waste separation, storage &handling, containment, placards, chemical inventory, emergency equipmentand procedures, sampling & monitoring needs etc.

11.7 All Operating Facilities, Buildings including Control Rooms, Offices,Workshops, Warehouses, Construction Sites, etc. shall be audited as per

agreed frequency.11.8 The buildings (etc.) may be grouped depending upon the area, size, usage

and/or location.

11.9 For Multi-storey Buildings, audit should be carried out floor wise andconcerned Managers (located on the floor to be audited) or equivalent shallassign the representative to accompany the auditors.

11.10 For New/Expansion Projects / Construction Worksites: Project Owner inconsultation with Project Executing Division/Department and HSE Departmentshall coordinate for the Audit as deemed necessary. Construction Contractorshall be involved. Refer to ZonesCorp CoP on Construction H & SManagement Plan (CoPS01)


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12 EHS AUDIT PLANNING

12.1 The personnel responsible for conducting EHS audits within the organizationshould:

a. Establish the audit objectives, criteria, extent, and scope;

b. Define responsibilities of the audit team, allocating adequate resources,and developing suitable procedures;

c. Implement the audit plan or program;

d. Maintain records to demonstrate implementation of the audit programme;and

e. Monitor the implementation of the audit plan or program and review theaudit plan or program at various stages to determine whether theobjectives have been met and to identify areas requiring improvement, orthat can be improved.

12.2 To make the EHS audit an effective tool that produces reliable information foran organization to improve on its environmental health and safetyperformance, EHS auditors must uphold the following principles of auditing:

a. Ethical conduct

b. Fairness when presenting audit findings;

c. Exercising due care and professionalism when conducting the audit;

d. Freedom from bias and partiality; and

e. Utilising the logical, scientific, evidence-based approach for arriving atreliable audit conclusions.


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13 MANAGING THE AUDIT PROGRAM

13.1 The audit program should be designed, developed and implemented inaccordance with, but not limited to, the following series of standards:

a. ZonesCorp / Tenant(s) EHS MS Targets & Objectives

b. ISO 14000 series for Environmental Management Systems;

c. ISO 18000 series for Occupational Health & Safety ManagementSystems;

d. OHSAS 18001 series for Occupational Health & Safety AssessmentSeries;

e. ISO 19011 - Guidelines on quality and/or environmental managementsystems auditing;

f. ISO 9000 series for Quality Management Systems (optional); and

g. Relevant standards for Risk Management Systems (optional).

13.2 Authority for conducting random or targeted EHS audits must be granted byEntitys senior management.

13.3 An audit program may include one or more audits depending upon the size,

nature, and complexity of the organization to be audited.13.4 An audit program also includes all activities necessary for planning and

organizing the type and number of audits and for supplying adequateresources to conduct the program effectively and efficiently within thespecified timeframe.

13.5 In addition to their internal audit program, organizations should also arrangeexternal audits of their EHS MS. External audits may be useful in providing amore independent assessment of performance and may employ expertise notavailable in-house.

13.6 Figure 13.1 illustrates the process-flow for the management of an audit

program based on the plan-do-check-act methodology described in ISO19011:2003 (Guidelines for Quality and/or Environmental ManagementSystems auditing).

13.7 Appendix 3presents a set of requirements recommended for use in EHS MSAudits and Self Assessments. This is based upon the Eight Elements ofZonesCorp EHS MS and the associated expectations


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Figure 13.1: Process Flow for the Management of The Audit Program

Authority for the auditprogram

Establishing the audit program1. Objectives and extent2. Responsibilities3. Resources4. Procedures

Implementing the audit program

1. Scheduling the audits2. Evaluating auditors3. Selecting audit teams4. Directing audit activities5. Maintainin records

Monitoring & reviewing the audit program

1. Monitoring and reviewing2. Identifying needs for corrective

and preventive action3. Identifying opportunities for

improvement

Improving theaudit program

Audit activities

Act

Plan

Do

Check


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14 CONDUCTING THE AUDIT

14.1 EHS Management System Audits

14.1.1 EHS MS Internal Audit (Self Assessments)

EHSMS Internal Audits should be carried out by the Entitys EHS Audit Teamat least on annual basis or at the frequency approved by senior managementin consultation with facility HSE staff

14.1.2 EHS MS External Audit (3rdParty)

Entities shall get their EHS MS audited by external 3 rdParty EHS Auditors

approved by ZonesCorp/EAD on at least annual basis.

The report of such Audits shall be submitted to ZonesCorp as a part of EHSPerformance. Refer to ZonesCorp Code of Practice on EHS PerformanceMonitoring & Reporting (CoP-EHS06)

14.1.3 EHS MS External Audit (ZonesCorp)

ZonesCorpAudit Team as a normal course shall undertake an IndependentAudit of Entitys EHS Management System at least once in three years.However ZonesCorp reserves the rights to increase the frequency as andwhen required on a case to case basis.

14.1.4 Minimum requirements that need to be verified during the EHS MS Audit areprovided as guidelines in Appendix 3

14.1.5 EHSMS Internal & External Audit schedules indicating time, location, area,suggested team leader etc. shall be prepared by Entities and communicatedto all concerned including ZonesCorp, Internal Audit Team Leaders andMembers etc.

14.1.6 ZonesCorp may like to nominate an observer during any of such Audits.

14.1.7 All EHSMS Audit Reports including Self Assessment and External shall besubmitted to ZonesCorp EHS.

14.2 EHS Audits (Safety Audits)

EHS Audits commonly known as Safety Audits should be carried out byEntitys Internal EHS Audit Team at least on monthly basis or at the frequencyapproved by Senior Management in consultation with facility HSE staff

Minimum requirements that need to be verified during the EHS Audits areprovided as guidelines in Appendix 4

14.2.1 Audit schedule for the year indicating time, area and suggested team leadershall be prepared and communicated to Auditee(s) (Area/Facility Owners),Audit Team Leaders, Members, etc.


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14.2.2 If audit of a particular area is not possible due to unavoidable circumstances

like shut down, maintenance etc. then this shall be rescheduled by the teamleader in consultation with the Auditee.

14.2.3 EHS Audit checklist should be used by each member of the audit team duringthe audit.

14.2.4 FM-ZCEHSCOP11-01 andFM-ZCEHSCOP11-02presents the recommendedchecklists for facilities and buildings respectively

14.2.5 ZonesCorp may ask Entities to submit or present the EHS Audit Reports

14.3 Audits Key Requirements

a. Auditee (Area / Facility Owner etc.) shall be informed about Audit

timings and Scope in advance by Audit coordinator (HSErepresentative etc.) and shall be required to accompany the audit team.

b. Audit team should comply with the applicable personal protectiveequipment requirement and operating facilities basic safety rules.

c. Auditee shall provide all the information / evidence as required duringthe audit.

d. Auditee shall take notes during the audit for all concerns raised by theaudit team.

e. Previous audit reports shall be provided to the audit team and reviewed

by the audit team before the audit.

f. Audit team may take these reports along with them during the audit forconfirming the previous recommendation compliance etc.

g. Audit team members may carry out a joint audit of all fields within auditscope or each / some members may assign to audit separate fields asper requirement and decision prior to start the audit.

h. If audit team is performing audit on separate field bases then theAuditee shall ensure all required arrangements like availability ofconcern representative etc.

i. An important aspect of the EHS Audit is onsite conversation with theemployees.

j. The auditor shall talk with employees about EHS aspects, hazards,practices, safety knowledge and any other concerns related to the job.

k. Auditors should also inquire about what actions the employee thinksshould be taken to safeguard the job.

l. A closeout meeting of Audit Team shall be held after conducting theaudit for discussing / consolidating the observations


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15 EHS MANAGEMENT SYSTEM AUDIT COMPLIANCE SCORE

15.1 The table provided below is recommended for use in assigning theCompliance Scoresto each of the EHS Management System Elements andRequirements

15.2 When reviewing the implementation extent for each of the requirement /expectation, a score (as per Table below) should be given, which reflects thestage of implementation.

15.3 While assigning the scores, auditors shall perform a careful review of auditfindings and implementation status in consultation with the Auditee(s):

15.4 There are 5 distinct levels:

Score Definition

0

There is no evidence that the Expectation is recognised to be anEHS MS requirement.

There is no implementation action ongoing or planned.

1

The Expectation is recognised to be an EHS MS requirement butis only partially being complied with and shows significant gapsand weaknesses.

There is no adequate plan to implement this Expectation beyondthe current level of compliance.

2

The Expectation is already partially implemented and there is anadequate plan in place to fully implement it.

Implementation progress is less than originally planned.

3

The Expectation is being implemented and there is an adequateplan in place to fully implement it.

Implementation progress is in accordance with or better than theplan.

4

The Expectation is currently fully met with negligible non-

compliance.

There are adequate systems in place to ensure continuouscompliance and improvement.

15.5 The Score should be assigned to each of the requirements agreed to be partof the audit scope. This shall be reflected clearly in the Audit Report. .

15.6 To arrive at the appropriate Score, auditors should use the informationobtained from site visits, interviews and documentation reviews. Also,information may be obtained from other Audit Team members as appropriate.


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16 DOCUMENTING THE EHS MS AUDIT FINDINGS

16.1 The audit findings may be considered as Gap or Weakness in themanagement system.

16.2 The documented audit findings must relate to the gaps/weaknesses whichhave been identified for the EHS MS Expectations / Requirements.

16.3 Audit findings should provide the detail as required by the Auditee to arrive ata rectification action plan.

16.4 Efforts should be made to ensure that the manner in which the Gaps arereported is stand-alone i.e. the Auditee should be able to interpret the Gap

without having to relate to the body of the audit report, the audit checklists orany other working papers.

16.5 No reference should be made to the way how the finding is to be corrected orthe time-frame in which this correction is to be implemented. Both of theseshall strictly Auditee responsibilities.

16.6 All audit Findings shall be risk classified in accordance with the definitions asper Table 16.1 below, which has been derived from the Risk Potential Matrixprovided in Fig 16.1. For detail refer to ZonesCorp COP on RiskManagement CoP-EHS06

16.7 The margins between the risk areas in the matrix are relatively large and assuch should not cause substantive arguments regarding the extent ofprobability or severity.

Table 16.1: Risk Weighting Factors for EHS MS Items

Risk Definition

E

Extreme

An item with an unacceptably high risk potential. It may exposethe Entity to intolerable losses to people, Assets, environment orreputation.

The gaps or weaknesses must be brought to the attention of

management. Immediate action should be taken to rectify it, i.e.reduce the risk to a tolerable and ALARP level.

H/M

High/Moderate

An item with a risk potential which falls in the highest part of theALARP risk management area.

The gaps or weaknesses, although not resulting in unacceptablyhigh risk levels, must be brought to the attention of management.

High priority action must be planned and documented to satisfyALARP risk management criteria.


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Table 16.1: Risk Weighting Factors for EHS MS Items

M

Moderate

An item with a risk potential which falls in the lower part of theALARP risk management area.

The gap or weakness must be rectified as a medium priority as tosatisfy ALARP risk management criteria.

L

Low

An item with a low risk potential.

The gap or weakness is tolerable without further action.Correction may improve process, system or organisationeffectiveness/efficiency.

FIG 16.1: RISK ASSESSMENT MATRIX (RAM)

Consequence2

Probability2 Insignificant(1)

Minor(2)

Moderate(3)

Major(4)

Catastrophic(5)

Rare (1) 1 2 3 4 5

Possible (2) 2 4 6 8 10

Likely (3) 3 6 9 12 15

Often (4) 4 8 12 16 20

Frequent (5)Almost Certain

5 10 15 20 25

15 25ExtremeRisk1

Activity or industry should not proceed in currentform

8 12 High RiskActivity or industry should be modified to includeremedial planning and action and be subject todetailed EHS Assessment

4 6ModerateRisk

Activity or industry can operate subject tomanagement and / or modification

1 3 Low Risk No action required, unless escalation of risk ispossible

1: Riskis the multiple of Probability & Severity of Consequence

2: Probability: Refer to Table 8.1 above for getting definition of Probability ofOccurrence

3: Consequence: Refer to Table 8.3 for Potential EHS Impact & Potential IncidentConsequence Rating


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17 .AUDIT REPORT

17.1 Audit results must be documented to identify existing deficiencies andrequired corrective actions.

17.2 Before being closed out, corrective action requests should be followed up toensure that non-conformance has been corrected. Similarly, the qualitysystem should also be corrected, if necessary, to prevent recurrence.

17.3 Based upon the working documents, check lists, audit observations andmeetings discussion, an audit report shall be prepared by Audit Team andapproved by the Team Leader.

17.4 Audit findings shall be communicated to Auditees at the end of the audit inthe close out meeting

17.5 Audit report shall reflect the points of concern, action required for rectification,recommendations, responsibility and the target date.

17.6 Audit team shall make efforts to record the actual facts during the audit andthe same may or may not be agreed by the Auditee(s); however theobservations and findings of the Audit Team can not be challenged.

17.7 EHS MS Audit Reports (Internal & External) Copies shall be forwarded toZonesCorp

17.8 One copy of the audit report should be forwarded to the Auditee.

17.9 Auditee(s) should follow up for rectification of audit observation and submitstatus report to Team Leader / concerned Management.

17.10 Original report along with the checklist shall be maintained by designateddepartment like HSE for recordkeeping and follow up for recommendation.

17.11 HSE Manager or equivalent shall share the audit results with organizationsenior management, if deemed necessary.

17.12 Quarterly report indicating the status of audit conducted, salient observations,recommendations and the status of actions should be prepared and shared

with concerned management.

17.13 Audit Reports shall be kept for presentation to external auditors (ZonesCorp,EAD, etc.) as and when required.


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18 EHS INSPECTIONS

18.1 EHS inspections are a basic tool for establishing and maintaining safeconditions and discovering unsafe practices in the workplace.

18.2 Systematic inspections are practical ways to identify and correct unsafeequipment, conditions, processes, and work practices. If unsafe conditionsand practices are found to exist, prompt corrective actions are initiated. Theyare an excellent way to prevent accidents from occurring and to safeguardemployees.

18.3 An additional benefit occurring from inspections is that they give employees

an opportunity to point out deficiencies in their area that may otherwise gounnoticed and uncorrected.

18.4 EHS inspections are conducted primarily not to find out how many things arewrong, but rather, to determine if things are satisfactory. Their secondarypurpose is to discover conditions that, when corrected, will bring the facility upto accepted and approved standards and/or regulations. As a consequence,the inspected facilities should become safer and more healthful places towork.

18.5 First-line supervisors, individual employees, maintenance employees, as wellas inspection teams, all function as workplace inspectors. The first-linesupervisor is one of the most important inspectors in the entire organization.He or she is more important to EHS than is the EHS inspection team.

18.6 The supervisor is the key person because he or she is in constant contactwith employees and is thoroughly familiar with all the safety risks that maydevelop in the department.

18.7 Supervisors should be on the alert at all times to discover and correct unsafeconditions and practices.

18.8 Employees, if they are on the alert, also can be of great value in preventingaccidents. Employees should be encouraged to inspect the workplace every

day and to report any hazardous conditions to their supervisor. Employeeswho are safety conscious will look continuously for conditions that may causeinjury to themselves or others.

18.9 Maintenance employees, in particular, should be safety conscious. Whenmaintenance employees are working in various departments and observesafety risks that should be corrected, they can avert hazards by reporting risksto the supervisor of the department. Management should alert its employeesthat maintenance people are a great help in locating and correcting hazardousconditions.


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19 EHS INSPECTIONS PROGRAM

19.1 EHS Inspections mainly differs from EHS Audits in areas like Scope,Frequency, Team Structure, Depth or Detail however the sections outlinedunder EHS Audit shall be considered for necessary guidance as applicableto various activities of EHS Inspections,

Inspections refer to a physical walk-through of an area conducted by eitherthe internal team of an organisation or by an external agency to determinecompliance with regulations and/or industry policies. A simple checklist can beused for the purpose. FM-ZCEHSCOP11-03 presents the recommendedformat for EHS Inspections)

19.2 Organizations should establish, implement, and maintain documentedprocedures for planning and conducting ongoing inspection, testing, andmonitoring related to EHS goals and targets set earlier. The frequency of suchinspection and testing should be appropriate to each item inspected, tested ormonitored.

19.3 In order for the EHS strategy to be effective, it is essential that inspections beplanned and systematic. This does not remove responsibility fromorganizations to be vigilant in recognizing and correcting issues that theybelieve may cause harm or damage.

19.4 At the completion of each inspection, any deficiencies identified must benoted on a summary sheet for action.

19.5 The supervisor (or equivalent) should then be de-briefed on ways to addressthe key issues identified, the personnel recommended to undertake specificactions and those responsible for notifying the person(s) responsible for EHS.Any issues that are identified as continuing must be reported to the areamanager and to the person(s) responsible for EHS.

19.6 It is the responsibility of each organization to develop, with their work teams,the most efficient manner in which such inspections will be performed. Theminimum requirement is that a written procedure for inspections is developed.

19.7 Figure 19.1 illustrates the process flow for coordinating workplace safetyinspections schedules.

19.8 To have a program for EHS inspection for reviewing work practices /workplace hazards throughout the organization and addressing the unsafecondition/act through the reports which shall be monitored and tracked forrectification.

19.9 The objective of Safety Inspection / Walk Thru is to maintain a Safe WorkingEnvironment (by identifying, controlling & removing hazards) and ensuring theimplementation of Safe Work Practices.


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Figure 19.1: Coordinating A Workplace Safety Inspection Schedule

Step 1: Develop register of activities occurring in theorganisations area of responsibility in consultation with theEHS committee or Equivalent.

Step 2:Identify inspection, testing, and monitoring requiredand frequency and competency by checking industry policies,legislation, and standards.

Step 3: Appoint a staff member to assist in developing plansand schedules of inspections, testing, and monitoring thatdetermine whether certificates of competency are needed.

Step 4: Coordinate the implementation of the inspection,testing, and monitoring schedule and ensure results aredocumented, reviewed, and acted upon and records are filedin a systematic manner.


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19.10 Entities shall perform Level 3 EHS inspections to supplement the formal EHSaudit process. There are two types of EHS inspection:

19.10.1Supervisory Inspections

a. Supervisory inspections are an essential part of the routine supervisorywork scope. Gaps and issues detected during these inspections shall beinvariably rectified on-the-spot or within a short time frame. There is norequirement to formally document supervisory inspection findings.

b. The responsibility for supervisory inspections shall be the Section Heador equivalent. Supervisory inspections shall be conducted by First LineSupervisors.

19.10.2Management Inspections

a. Management inspections are an essential part of the managementprocess. The term management refers to Senior Managers and above.

b. Management inspections are a key component of the HSE assuranceprocess in which senior management physically verify that operationsare conducted in accordance with policy, standards and procedures.

c. The results of management inspections shall be formally documentedand effective follow-up shall be verified.

d. Management EHS inspections provide excellent opportunities to:

Convey management EHS commitment and leadership messages tothe workforce.

Physically verify the correctness of formal progress and achievementreports.

Create awareness of general attitudes and concerns of the workforce.

e. Management inspections, if conducted properly, enhance EHS teamwork, workforce culture and willingness to change and improve.

19.11 EHS INSPECTIONS SCHEDULE

Each Area (facility) owner in consultation with HSE Staff shall prepare SafetyInspection Schedule for the whole year. This shall at least include scope,proposed Dates, Time and Locations/Areas

19.12 CONDUCTING EHS INSPECTIONS:

a. EHS Inspections shall at least be carried out jointly by HSE, Area/FacilityOwner and Maintenance Representatives.

b. For Building Safety Inspection each Division/Department located atrespective floor shall nominate a representative for participating inInspections

c. Buildings Fire Wardens or equivalent shall also be the team members.


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d. For Projects (New or Expansion)/ Construction Sites: Contractor

representatives shall be part of the facility inspection team. However thecontractors shall conduct independent inspections as well and maintainrecord. This shall be in accordance to ZonesCorp Code of Practice onEHS Management of Contractors ZC-CoP-EHS09

19.13 EHS INSPECTION REPORTS

19.13.1 EHS Inspection Reportshall be filled-up by the appointed representativeindicating the inspection finding, action required and the responsibledepartment / section.

FM-ZCEHSCOP11-03 presents the recommended format for EHS

Inspections)Area owner / Fire Wardens shall distribute the copies of the EHS Inspectionreport to the responsible section / group for execution of marked actions.

A copy of each inspection report should be kept with HSE Department.

19.13.2 EHS Inspection Status Report

All the EHS inspection reports shall be consolidated in Monthly SafetyInspection Report

The actions marked in corrective action column shall be tracked to ensure

that the recommendations are acted upon and accomplished.The remarks column shall be filled with DONE, IN PROGRESS or anyapplicable remarks - this column shall serve as the Action Taken statusindicator.

19.13.3 Monthly / Cumulative EHS Inspections Statistics Report

The Monthly / Cumulative Safety Inspections Statistics report shall beprepared for sharing with Senior Management and keeping track of actionitems.

This report shall reflect the no. of Inspections planned in the month, actual

no. of inspections that has been carried out, no. of recommendations madeand the status of recommendations (in progress or closed).

Both the monthly and year to date status of all these information shall bepresented in the report.

In each report the status of previous months In Progress Actions should beupdated.


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20 REFERENCES

20.1 Abu Dhabi Emirates EHS Management System Manual

20.2 ZonesCorp Code of Practice on EHS Management System Framework

20.3 ZonesCorp Code of Practice on EHS Incident Reporting & Investigation

20.4 ZonesCorp Code of Practice on Operation Environment Management Plan

20.5 ZonesCorp Code of Practice on Pollution Prevention & EnvironmentalCompliance Assurance

20.6 ZonesCorp Code of Practice on EHS Compliance Enforcement

20.7 ZonesCorp Code of Practice on EHS Impact Assessment (EHSIA)

20.8 ZonesCorp Code of Practice on EHS Risk Management

20.9 ZonesCorp Code of Practice on Integrity Assurance & Management

20.10 ZonesCorp Code of Practice on EHS Management of Contractors

20.11 ZonesCorp Code of Practice on EHS Performance Monitoring & Reporting

20.12 ZonesCorp Code of Practice on Waste Management

20.13 ZonesCorp Code of Practice on Health Surveillance & Monitoring

20.14 ZonesCorp Code of Practice on Operation Health & Safety Management Plan


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APPENDIX 1

EHS COMMITMENT & POLICY

Industrial Sector within Abu Dhabi Emirate shall:

1. Strive to protect the Environment and the Health and Safety (EHS) ofEmployees, Contractors and the Community by sharing responsibility atall levels within Industrial Sector in the Emirate of Abu Dhabi

2. Develop an Institutional Framework for effective enforcement of NationalEHS Policies & Regulations across the Industrial Sector within Emirate ofAbu Dhabi

3. Ensure that the Health, Diversity and Productivity of the Environment ismaintained or enhanced for the benefit of future generations in order toachieve sustainable development.

4. Achieve sustainable development by promoting the concept of CleanerProduction, Energy Conservation and Industrial Ecology.

5. Integrate EHS Risk Assessment & Management in Planning,Development & Operation of all Projects

6. Integrate Economic, Social, Environmental, Health and Safety

considerations including conservation of Biological Diversity andEcological Integrity into decisions making process for IndustrialDevelopment

7. Ensure responsible care and management of Environment Health andSafety concerns including the ultimate disposal of any Wastes throughoutthe life cycle of the Project.

8. Ensure that the cost of abatement of Pollution and Health Risk is borneby the Polluter and Risk Generator.

9. Ensure commitment of reducing EHS Liabilities and Improving Efficiency

or Resource use.10. Promote awareness across Industrial Sector within Abu Dhabi Emirate

about their responsibility in protecting the Environment and the Healthand Safety of the Community.

11. Ensure an effective Emergency Response Preparedness for the IndustrialSector is in place and maintained at all times.

ZonesCorp and Industrial Sector Entities shall implement this Policy through adocumented Environment, Health and Safety Management System (EHSMS)and conduct periodic audits for compliance assurance.


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APPENDIX - 2

ABU DHABI EMIRATE INDUSTRIAL SECTOR EHS REGULATORY FRAMEWORK

This appendix presents a partial list of EHS Regulatory Framework Codes ofPractice and Guidelines for Industrial Sector within Abu Dhabi Emirate. The list willcontinue to be subject to considerable change during the next few years, to matchthe requirements of Industrial Sector

Sr.No.

Code of Practice & Guidelines Document No.

Environment Health & Safety (EHS)

1 EHS Management System (EHSMS) Framework CoP-EHS01

2 EHS Management System CoP-EHS02

3 EHS Risk Management CoP-EHS03

4 EHS Impact Assessment (EHSIA) CoP-EHS04

5 EHS Accident/Incident Reporting & Investigation CoP-EHS05

6 EHS Performance Monitoring & Reporting CoP-EHS06

7 EHS Management of Industries CoP-EHS07

8 EHS Management of Workers Residential Cities CoP-EHS089 EHS Management of Projects CoP-EHS09

10 Integrity Assurance & Management CoP-EHS10

11 EHS Audits & Inspections CoP-EHS11

12 EHS Compliances Assurance & Enforcement CoP-EHS12

13 EHS Training & Awareness CoP-EHS13

Environment

1 Construction Environment Management Plan (CEMP) CoP-E01

2 Operations Environment Management Plan (OEMP) CoP-E02

3 Waste Management Plan CoP-E03

4 Pollution Prevention & Environmental Compliance Assurance CoP-E04

Health

1 Occupational Health Surveillance and Monitoring CoP-H01

2 Occupational Health Welfare Management CoP-H02

3 Food Safety Management CoP-H03


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Sr.No.

Code of Practice & Guidelines Document No.

Safety

1 Construction Health & Safety Management Plan (CHSMP) CoP-S01

2 Operation Health & Safety Management Plan (OHSMP) CoP-S02

3 Transport Management Plan (TMP) CoP-S03

4 Contractors Safety Requirements CoP-S04

Fire & Emergency

1 Fire Risk Management (FRM) CoP-FE012 Fire Protection System Design Criteria CoP-FE02

3 Emergency Response Plan (ERP) CoP-FE03

4 Emergency Communication CoP-FE04

5 Crisis Management Plan (CMP) CoP-FE05

6 Incident Command System (ICS) CoP-FE06

Code of Practices Guidelines

1 EHS Manual for Workers Residential Cities CoP-GL05


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APPENDIX 3

EHS MANAGEMENT SYSTEM AUDIT BASIC REQUIREMENTS

Section 1: Leadership and Commitment

ESSENTIAL ITEMS TO BE CHECKED

Leadership and Commitment

Commitment toEHS aspectsthroughleadership

Senior management should engender commitment to EHS issues atall levels through their personal style of leadership and management.Key elements include:

Visible expressions of commitment by senior people EHS matters should be placed high on personal and collective

agenda

All senior managers should set a personal example to others.They should be, and seen to be actively involved in EHS matters,e.g. attendance at EHS meetings, personal instigation of EHSaudits and reviews, etc.

A feedback system should be established to encourage andfacilitate employee feedback on EHS matters

A positive culture should be promoted at all levels

Section 2: Policy and Strategic Objectives

EHS Policy Statement

General Written EHS policy

Dated and signed by Chief Executive

Policy statements:

specific to individual parts of the contract (e.g.locations/sites/plants)

cover specialised aspects (e.g. alcohol and drugs)

consistent with Tenants standards and guidelines clear, concise and motivating

Content Importance of EHS as a contract objective

Incidents and injuries are unacceptable

EHS established as a line management responsibility

Everyone is responsible for their own and their colleagues' EHS atwork


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Distribution/availability

EHS policy distributed to all concerned, i.e.

handed to each employee by their line manager when issued

All new employees handed a copy by their line manager

displayed on notice boards at each work location(worksites andoffices)

copies provided for each entity on the contract(includingsubcontractors, suppliers and agents)

available to Tenant and contractor employees in their workinglanguage(s)

Discussion Policy and its implementation when issued discussed by linemanagers with each employee

Section 3: Organization, Resources and Competence

EHS Organization

Key personnel Personnel responsible for the implementation of EHS objectivesclearly identified in an organisation chart

Responsibility adequately covered during all phases of contract

Job descriptions in place showing each team member's EHScompetencies, responsibilities and function

Organisation clearly shows position of EHS professionals

EHS objectives/accountability

Defined to meet health, safety and environmental objectives as wellas those of time, cost and quality

Accountability for EHS success and equally of any failure clearlystated

Focal point within the team structure ensuring that all EHS mattershave been identified

Designated team leader to produce EHS objectives, tasks and targetsfor the organization

Targets, etc to be realistic and consistent EHS issues

Manning/Communication

Manpower philosophy

Manpower level to be defined correctly so as not to compromise EHS

Effective means to communicate EHS issues between the Tenant,contractor and subcontractors

Organisation staffed by competent personnel with sufficientappreciation of EHS where necessary with specific training in theissues involved


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CorporateStructure/Responsibility

Entity's expectations on EHS Management shall be communicated indepth within the organization

Access of line management to their corporate management structureon EHS issues to be defined

Level of handling EHS issues by the Entity corporate structure (middleor senior management or board level)

In the Tenants corporate organisation, individuals charged withresponsibility for EHS at middle senior manager or board memberlevel

Access to specialist EHS advice for line management, e.g. Provision of EHS documentation

Employment of EHS specialist

EHS Professionals

Job definition Role of the EHS advisers / specialists well defined

Job description drafted

Reporting/follow-up

Reporting relationship with line management

Direct access to the Chief Executive

Does line management follow advice offeredEHS Communication within organization


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EHSDepartment orEquivalent

Entity's EHS department involved in:

Preparing and monitoring departmental action plans

Formulation and suitability of EHS rules

Planned inspections and audits together with line management

Promotional material

EHS training

Subcontractor assessment

Training and auditing

Health risk assessment, health performance monitoring and healthsurveillance

Environmental monitoring

Supporting incident investigation by line management

Guidance given by the EHS Professional in preparing andimplementing:

Operating and emergency manuals

Emergency plans

Training for fire fighting teams, first-aiders, etc

Emergency drills and exercises

Protective equipment and rescue

Contact and liaison with relevant Government departmentsmaintained

Contractors Control

Management Verify availability and compliance to ZonesCorp EHS Code ofPractice on

EHS Management of Projects CoP-EHS09

Contractor Safety Requirements CoP-S04

Construction Health & safety Management Plan CoP-S01

To be well integrated and identified in Contract EHS Plans

Contractor(s) EHS Plans to be vetted for suitability by concernedManagement

Vetting of past contractors / subcontractor records

Maintenance of approved contractors lists where EHS has beenconsidered


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Coverage/Awareness

Set up appropriate lines of communication to handle EHS issues, e.g.such items as:

Direct access to emergency services

Nearest hospital

Ambulance Services

First Aid Facilities, etc

Emergency Services: those organisations that would be expected toprovide support in a major incident aware of requirements Briefed asto their likely role

ConstructionProjects

Verify availability and compliance toConstruction EHS Management Plan

Construction Environment Permit

Construction EHS Manual

Refer to ZonesCorp Code of Practice on Construction EnvironmentManagement Plan (CoP-E01) and Construction Health & SafetyManagement Plan (CoP-S01)

EHS Communications

Coverage/Awareness

Set up appropriate lines of communication to handle EHS issues, e.g.such items as:

Direct access to emergency services

Nearest hospital

Ambulance

First aid Centre, etc

Authorisation and implementation procedures fully understood

Emergency services: those organisations that would be expected toprovide support in a major incident aware of requirements

Briefed as to their likely role

External links Lines established to communicate externally incidents that may

endanger those on a site

Government agency reporting procedures and the associatedresponsibilities of Employees & Contractors

Ability of base to mobilise in an emergency, e.g. doctors, hospitalfacilities

Emergencycommunication

Appropriate for incidents envisaged

Strengthened, duplicated or backed up by other means

Able to communicate with all the workforce in an emergency

Communications take into account the diversity of languages amongst

the workforce


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EHS Meeting Programme

Scheduling Entity(s) to establish a regular schedule for EHS meetings

Procedure to maintain records of personnel attendance

Managementparticipation

Managers / Supervisors seen to be involved by employees in:

EHS activities, objective setting and monitoring

Taking action and providing resources to support their statedpolicies and objectives

Meeting

structure

EHS meeting structure

Effective to manage and communicate on EHS

Allow employees full involvement and their own ideas to be heard

Typical agenda and meeting formats

Follow-upactions

Meeting actions

Where action is agreed, is it seen to be carried out?

Where action is not agreed, is it explained why?

Communication Results of EHS activities, both successful and less successful, openlycommunicated to all employees

Meeting programme consistent with the rest of the managementstructure to communicate effectively EHS issues

Meetings recorded clearly and consistently

Structured to differentiate between health, safety and environment

EHS Promotion and Awareness

Techniques Appropriate communications techniques used to make the personnelaware of EHS issues

How this is to be implemented, e.g.

Personal contact

Interactive video

Notice-boards

Newsletters (suitable for large sites)

Bulletins

Posters

Performance EHS Performance Boards at designated locations

EHS Performance Recordkeeping

PerformanceImprovement

Possibilities include:

Small 'give-aways' with the EHS message

Competitions


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Suggestion schemes

Part of business EHS activities seen as an integral part of running an efficient businessrather than a costly and time-consuming 'extra'

EHS Competence Requirements

Fitness ofpersonnel

Confirmation of medical fitness from recognised / approved medicalfacility of all employees proposed for contract

Employee Orientation Programme

Approach Provision of a comprehensive EHS handbook for all new employees

On-the-job orientation for supervisory staff

Established procedure in relation to follow-up of all new employees atthe worksite

New employees Adequately trained and confident of their own abilities

Coached to improve their work practices rather than blamed formistakes

Accountability Employees know they are accountable for EHS performance

Aware that their EHS performance is part of the organization'sappraisal and reward system

Know that flagrant or frequent breaks of published EHS rules willresult in disciplinary action

Procedures Required for new employee orientation consistent with Tenantsexisting standards and guidelines

Reappraisal Programme subject to appraisal and review

EHS Training (General)

Entity Standards Statement on the current standard of workforce and trainingrequirements to meet Entitys standard

EstablishedTraining Program Including: EHS management

Work (Job) related procedures

Road safety

Health (first-aid, health hazards, medical services, alcohol anddrugs, health promotion, use of PPE)

Auditing

Incident investigation and reporting

EHS adviser skills

Supervisory development


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Environmental protection

SupervisoryTraining

Supervisory development training promotes man-management skillsand communication skills

Formalisedprogramme

Formal EHS orientation programme for employees working on- site

Records kept of employees who have been through the programme

Employees trained before starting work

Training covers those joining as a contract is being implemented

Coverage EHS training of employees coverage (including):

Safety

Fire and explosion

Road transport/driving

First-aid

Work Procedures

EHS Procedures including / Permit to Work

Hazard awareness and reporting

Occupational health

Security

Basic EHS Rules Legislative requirements

Environmental Protection

Supervisors'participation

Supervisors required to brief and debrief staff before and after trainingcourses

Course content Effective system for establishing the need for and the content oftraining courses

Determining course effectivene