Regulatory Compliance Ver. Training Pack 2


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  • Basically, procedures, policies and standards are internal frameworks that guide the way our business should be conducted.That is adhering to internal policies and procedures. Laws, Acts & Decrees are created by the government to inform us how well the government think we should run our business and as it affects our environment. We need to obey the laws in order to retain our LTO. Conventions & Treaties are agreement by organisations to adhere to certain policies as it affects a particular industry. Audits & Verifications are internal means by which Shell take stock of its operations to know their level of compliance to Laws, Standards , Conventions etc.
  • Types : This means the type of operation that is being carried out by the asset team e.g drilling, production, Seismic e.t.c. Terrain : This is a very important aspect to consider in selecting the set of regulation that will be applicable to an operation. The limit for certain monitoring parameter in the land is quite different from that of swamp and off shore. When we talk about terrain we are considering where the operation is sited i.e land, swamp or offshore. State of Operation : The state that a facility is situated also determines the type of applicable legislation that will affect the facility. Each state has their own set of regulation. Therefore as a company, we have to comply with all regulation and standard as applicable to our operations
  • Regulatory Compliance Ver. Training Pack 2

    1. 1. HSE Regulatory Compliance Verification Training Pack Module 2 for HSE Advisors & Line HSE Focal Points
    2. 2. Training Pack Module 2 As part of its Business Principles and Policies, SPDC is required to comply with all the relevant HSE Laws and Regulations enacted by the Federal, State and Local Governments of Nigeria. In addition to this, SPDC is required to comply with some international laws, conventions and protocols to which Nigeria is signatory; and all limits, criteria and other requirements subscribed to by SPDC, SIEP and the Shell Group, including international standards where applicable. Introduction:-
    4. 4. DEFINITION Statute , ordinance , judicial decision , executive order , or a regulation having the force and effect of law , that determines the legal standing of a case or issue . Applicable legislation are Statutes/regulations that are relevant or peculiar to a particular operation .
    6. 6. <ul><ul><li>Keeping an overview of HSE Compliance within SEPCiN. </li></ul></ul><ul><ul><li>Ensuring that all facilities and Projects meet the regulatory requirements and possess necessary permits / LTO’s within the context of the law. </li></ul></ul><ul><ul><li>Keeping the company abreast of situations that may lead to withdrawal of LTO. </li></ul></ul><ul><ul><li>Facilitating the application for & acquisition of required permits, exemptions & waivers for SEPCiN production facilities & processes. </li></ul></ul><ul><ul><li>Maintaining close liaison with Govt. statutory & regulatory bodies to negotiate in areas of non-compliance based on available objective evidences & best practices to seek for dispensation for non-complying items in order to sustain SEPCiN LTO. </li></ul></ul><ul><ul><li>Acting as SEPCiN corporate focal point for regulatory compliance in reporting to DPR and other Regulatory bodies. </li></ul></ul><ul><ul><li>Maintaining contact & liaison with Regulatory bodies and the OPTS on issues relating to H, S & E in the O&G industry. </li></ul></ul>Responsibilities of the HSE Compliance Team
    7. 7. <ul><li>Reporting to LTO Forum, HSE-SC, QBR & other such meetings on the compliance status of the company </li></ul><ul><li>Make the Functional Managers aware of HSE Regulations applicable to them. </li></ul><ul><li>Provide the Functional Focal Points with detailed knowledge of the HSE </li></ul><ul><li>Regulations applicable to them. </li></ul><ul><li>Organize meetings with Regulators and Execution Party May Participate. </li></ul><ul><li>Providing expert support to the line for ALL Regulatory compliance issues. </li></ul><ul><li>Plan and conduct compliance verification exercise of all line teams and </li></ul><ul><li>monitor action close out status. </li></ul><ul><li>Coordinates Regulator inspections, drills(planned and ad-hoc) etc and </li></ul><ul><li>participate in the events. </li></ul><ul><li>Deliver Awareness lectures on applicable legislation to the line on demand </li></ul>Responsibilities of the HSE Compliance Team Cont.
    8. 8. Key Regulatory Bodies <ul><li>DPR ( Department of Petroleum Resources) </li></ul><ul><li>FMEnv ( Federal Ministry of Environment) </li></ul><ul><li>NAPIMS (National Petroleum Investment Management Services) </li></ul><ul><li>NCAA (Nigerian Civil Aviation Authority) </li></ul><ul><li>NNRA ( Nigerian Nuclear Regulatory Authority) </li></ul><ul><li>NOSDRA ( Nigerian Oil Spill Detection Response Agency) </li></ul><ul><li>ITU (International Telecommunication Union) </li></ul><ul><li>OPTS ( Oil Producers Trade Sector) </li></ul>
    9. 9. Applicable Legislation <ul><li>SOURCES </li></ul><ul><li>NIGERIAN STATE LEGISLATION </li></ul><ul><li>FEDERAL NIGERIAN LEGISLATION </li></ul><ul><li>INTERNATIONAL LEGISLATION </li></ul><ul><ul><ul><li>Register of critical Legislation and HSE Compliance Procedure : HSE document centre. </li></ul></ul></ul>
    10. 10. OVERVIEW OF HSE REGULATORS & ISSUES COVERED BY REGULATIONS DPR ( Department of Petroleum Resources ) Organisation : Regulations : EGASPIN MOSR (Mineral Oil Safety Regulations) (Environmental Guidelines and Standards for the Petroleum Industry in Nigeria) Regulators Main Tasks: <ul><li>Develop and issue Regulatory Requirement on behalf of the Nigerian </li></ul><ul><li>Government related to Health, Safety and Environment. </li></ul><ul><li>Monitor and Confirm that the Nigerian Government Regulations are adhered too </li></ul><ul><li>Issue Permits and Waivers as deemed necessary </li></ul>NNPC DPR- West Warry DPR Head Quarters Lagos DPR- East Port Harcourt DPR Others EIA (Environmental Impact Assessment) PA (Pipelines Act)
    11. 11. Some Areas covered by EGASPIN by Department of Petroleum Resources <ul><li>Use of Radioactive Source </li></ul><ul><li>Monitoring of radio-active substances </li></ul><ul><li>Reporting of Radioactive sources to DPR </li></ul><ul><li>Identification of Hazardous waste/materials </li></ul><ul><li>Transportation of Hazardous Waste </li></ul><ul><li>Reporting of Hazardous waste to DPR </li></ul><ul><li>Waste Management (Release inventory/segregation) </li></ul>
    12. 12. Some Areas covered by MOSR by Department of Petroleum Resources <ul><li>Duties of licensees and lessees </li></ul><ul><li>Appointment of competent persons </li></ul><ul><li>Chemicals management (SHOC card) </li></ul><ul><li>Audiometric test </li></ul><ul><li>Display of Regulation </li></ul><ul><li>Personnel protective equipment </li></ul><ul><li>Injuries and first aid </li></ul><ul><li>Fire protection e.t.c. </li></ul>
    13. 13. Areas covered in some Applicable legislations <ul><ul><ul><li>Environmental Impact Assessment </li></ul></ul></ul><ul><ul><ul><li>Precaution to take before starting a project </li></ul></ul></ul><ul><ul><ul><li>Application for EIA </li></ul></ul></ul><ul><ul><ul><li>Exception for EIA </li></ul></ul></ul><ul><ul><ul><li>Identification of Environmental Issues </li></ul></ul></ul><ul><ul><ul><li>Requirements for EIA </li></ul></ul></ul><ul><ul><ul><li>Minimum content of EIA </li></ul></ul></ul><ul><ul><ul><li>Prohibition to carry out a project. </li></ul></ul></ul><ul><ul><ul><li>Penalty/fine </li></ul></ul></ul>
    14. 14. Areas covered by the Pipeline Act 2003 <ul><li>Permit to Survey Pipeline route </li></ul><ul><li>Application for license to construct and operate a Pipeline </li></ul><ul><li>Pipeline design & Standard </li></ul><ul><li>Construction Of pipeline </li></ul><ul><li>Commencement of inspection and testing of a pipeline </li></ul><ul><li>Operating and maintenance guidelines </li></ul><ul><li>Procedure for upgrading pipeline or changing substance transmitted by pipeline </li></ul>
    15. 15. <ul><li>NCC Act 2003 C 130-134 & 135-137 </li></ul><ul><li>Approvals ( Licenses, Contractor and Equipments) </li></ul><ul><li>Safety of Equipments </li></ul><ul><li>Competency of Installers and service providers </li></ul><ul><li>Protection of people & Environment </li></ul>Some Areas covered by NCC by Department of Petroleum Resources
    16. 16. FEPA – FMEnv & UD Federal Ministry of Environment & Urban Dev. Organisation : Regulations: Environmental Impact Assessment Regulations Regulators Main Tasks: <ul><li>Develop and issue Regulatory Requirement on behalf of the Nigerian </li></ul><ul><li>Government related to need for Environmental Impact Assessments. </li></ul><ul><li>Review and approve EIAs conducted </li></ul><ul><li>Issue Permits and Waivers as deemed necessary </li></ul>FMEnv- West Warry FMEnv Head Quarters Lagos FMEnv- East Port Harcourt
    17. 17. FML ( Federal Ministry of Labour) FML- West Warry FMLHead Quarters Abuja FML East Port Harcourt FML- Lagos Warry Organisation : Regulations: Factories Act Regulators Main Tasks: <ul><li>Develop and issue Regulatory Requirement on behalf of the Nigerian </li></ul><ul><li>Government related to need for Factories </li></ul><ul><li>Issue Permits / Certificates to operate a Factory </li></ul>
    18. 18. Some Areas covered by Factories Act <ul><ul><ul><li>The Powers of the Director of Factory </li></ul></ul></ul><ul><ul><ul><li>Vessel containing dangerous liquids. </li></ul></ul></ul><ul><ul><ul><li>Training and supervision of in-experienced workers </li></ul></ul></ul><ul><ul><ul><li>Hoists and lift </li></ul></ul></ul><ul><ul><ul><li>Lighting & Ventilation in a factory </li></ul></ul></ul><ul><ul><ul><li>Overcrowding in the factory </li></ul></ul></ul><ul><ul><ul><li>Cranes and other lifting machines </li></ul></ul></ul><ul><ul><ul><li>Safe means of access and safe place of employment </li></ul></ul></ul><ul><ul><ul><li>Safety provisions in case of fire e.t.c </li></ul></ul></ul>
    19. 19. NAPIMS National Petroleum Investment Management Service NAPIMS Head Quarters Lagos Organisation : Regulations: Contract Regulations Regulators Main Tasks: <ul><li>Develop and issue Regulatory Requirement on behalf of the Nigerian </li></ul><ul><li>Government related to Civil Aviations. </li></ul><ul><li>Conduct verifications to confirm that Regulations are fully implemented. </li></ul><ul><li>Requirements covers : </li></ul><ul><li>Need for registration of all contractors with NAPIMS </li></ul><ul><li>HSE in Contracts </li></ul>
    20. 20. NCAA Nigerian Civil Aviation Authority Organisation : Regulations: NCAA Act Regulators Main Tasks: <ul><li>Develop and issue Regulatory Requirement on behalf of the Nigerian </li></ul><ul><li>Government related to Civil Aviations. </li></ul><ul><li>Conduct verifications to confirm that Regulations are fully implemented. </li></ul><ul><li>Act covers : </li></ul><ul><li>Licenses </li></ul><ul><li>Height of Towers </li></ul><ul><li>Lighting requirements in towers ( 120m lights at the 4 base and top while 60 m just) </li></ul>NCAA- West Warry NCAA Head Quarters Lagos NCAA- East Port Harcourt
    21. 21. NNRA Nigeria Nuclear Regulatory Authority NNRA- West Warry NNRA Head Quarters Lagos Organisation : NNRA- East Port Harcourt Regulations: Nigeria Basic Ionizing Radiation Regulations Regulators Main Tasks: <ul><li>Develop and issue Regulatory Requirement on behalf of the Nigerian </li></ul><ul><li>Government related to storage and use of Radiation Equipment. </li></ul><ul><li>Monitor and Confirm that the Nigerian Government Regulations are adhered too </li></ul><ul><li>Issue Permits and Waivers as deemed necessary </li></ul>
    22. 22. Areas covered by NNRA by Nigeria Nuclear Regulatory Authority <ul><li>Use of Radioactive Source </li></ul><ul><li>Monitoring of radio-active substances </li></ul><ul><li>Reporting of Radioactive sources to DPR </li></ul><ul><li>Ensuring the Registration of site that Radio active sources are used. </li></ul>
    23. 23. NOSDRA Nigerian Oil Spill Detection Response Agency NOSDRA- West Warry NOSDRA Head Quarters Lagos Organisation : NOSDRA- East Port Harcourt Regulations: Environmental Spill / Clean-up Regulations Regulators Main Tasks: <ul><li>Develop and issue Regulatory Requirement on behalf of the Nigerian </li></ul><ul><li>Government related to detection and response to oil and chemical spills. </li></ul><ul><li>Conduct verifications to confirm that Regulations are fully implemented. </li></ul>
    24. 24. Other Regulations <ul><ul><ul><li>International Telecoms Union (ITU) Regulations </li></ul></ul></ul><ul><ul><ul><li>National Civil Aviation Authority (NCAA) </li></ul></ul></ul><ul><ul><ul><li>Standards Organisation Nigeria(SON) </li></ul></ul></ul><ul><ul><ul><li>DEP/OEM (Practices and Equipments standard/manual) </li></ul></ul></ul><ul><ul><ul><li>BCP (Group Guidelines, Rules & Regulation) </li></ul></ul></ul><ul><ul><ul><li>ICTU ACTS/NEMA ACT (Still in its development/Draft state) </li></ul></ul></ul>
    25. 25. Applicable Legislation <ul><li>Where do you find applicable legislation? </li></ul><ul><li>URL </li></ul><ul><li> </li></ul><ul><li>OR </li></ul><ul><li>Go through the document centre via the HSE Web site. Click on the following link HSE Assurance & Compliance HSE Compliance </li></ul><ul><li>International & Federal legislation or State legislation </li></ul>
    26. 26. OPTS Oil Producer Trade Sector Members of OPTS participate in review of regulations impacting on the oil producing companies in Nigeria. Several Groups have been formed to study different issues such as:- <ul><li>Production Water Disposal </li></ul><ul><li>Air pollution </li></ul><ul><li>Gas Flare Down </li></ul><ul><li>NESREA </li></ul>Benchmark and disseminate Best Practice
    27. 27. Oil Producing Trade Sector (OPTS) Structure Executive Management Committee SPDC Rep : Basil Omiyi Environmental & Safety Committee SPDC Rep: Carol Macauley SNEPCo Rep: Justice Derefaka Gas Flare Down Working Group JV Rep: Abdul Yammama SPDC Rep: Catherine Osharode Production Water Disposal Study Working Group JV Rep: SPDC Rep: Carol Macauley Air Quality Study Working Group JV Rep: SPDC Rep: Abdul Yammama NESREA Working Group JV Rep: SPDC Rep: Carol Macauley Legal Committee EPG Rep: TBA External Stake Holder Committee EPG Rep: TBA Others
    28. 28. HSE Regulator Focal Points:   No HSE Regulation Focal Point 1 MOSR All Members Of HSE Compliance Team 2 EGASPIN All Members Of HSE Compliance Team 3 FMEnv Remi   NCAA Lucky 4 NNRA Abdul 5 NOSDRA Caroline 6 NCC Tele 7 NAMA Lucky 8 Oil and Gas Pipelines Regulations Tele 9 NMA Chituru 10 FML Caroline 11 Explosives Act Chituru
    29. 29. Strategy and Plan For Compliance Verification in 2009 <ul><li>Identify Line Compliance Focal Points </li></ul><ul><li>Develop Training Packages. </li></ul><ul><li>Conduct Regulatory Compliance Training for Identified Line Focal Points. </li></ul><ul><li>Support Identified Focal Points in conducting First time verification. </li></ul><ul><li>Line Focal Points to send Verification Report to HSE Compliance Team for Quality Checks </li></ul><ul><li>Carry out Risk based Priority Compliance Verification Spot Checks with planned schedule for the Line. </li></ul><ul><li>Report NC’s to Line Manager/ TL and Monitor close out </li></ul><ul><li>Line loads NC’s into Fountain and ensure close out. </li></ul>
    30. 30. Steps involved in Conducting Reg. Compliance verification/ Audit. What is Reg. Compliance Verification:- Compliance Verification Exercise is a monitoring process as it seeks to assess how a team or facility is complying with the regulatory requirements guiding its operations at any point in time. Since new regulations will constantly be evolving, the steps set out here would be considered generic irrespective of which regulation is being monitored or verified for compliance. Planning The planning stage shall involve preparation of tracking matrices or such other simplified checklists for the Regulations to be verified and the publication of an agreed verification schedule.
    31. 31. <ul><li>Tracking Matrices: </li></ul><ul><li>At the commencement of each cycle (the year), the Principal HSE Compliance Advisor shall advise line teams on what Regulations to verify for that year. The criteria for choosing the Regulations to be verified will be based on the business needs and objectives as well as the industry’s critical concerns on Legal / Regulatory compliance for that year. </li></ul><ul><li>Any new Regulation shall also be considered top priority with respect to verification in order to ascertain the company’s baseline compliance status with its requirements. </li></ul>Steps involved in Conducting Reg. Compliance verification/ Audit.
    32. 32. <ul><li>Compliance Verification Schedule </li></ul><ul><li>A verification schedule, which details the teams to be verified, and period of verification shall be published by first quarter of every year. </li></ul><ul><li>Conducting the Audit </li></ul><ul><li>Opening meeting </li></ul><ul><li>It is mandatory that as a minimum, the HSE head of the Auditee or an appropriate representative be present at the meeting. The line team to be verified shall be responsible for all issues of logistics associated with the successful completion of the verification exercise. </li></ul><ul><li>Verification exercise: </li></ul><ul><li>The actual verification shall commence with a document review where elements of the Regulatory requirements applicable to the facilities will be agreed. Past verification reports and closeout status shall also be assessed at this stage. Site visits and interviews of personnel shall be used to obtain evidence of the teams’ activities to assess their level of compliance with the requirements. </li></ul>Steps involved in Conducting Reg. Compliance verification/ Audit.
    33. 33. <ul><li>Report of findings </li></ul><ul><li>Closeout meeting </li></ul><ul><li>Agreement by the Asset, Service or Line teams shall be expected on appropriate corrective actions to address the non-compliances identified in a timely and cost effective manner. </li></ul><ul><li>Attendance is mandatory for Asset or Line manager, his HSE Team Lead and other key team members at the close out meeting to challenge and accept the non-compliances raised. </li></ul><ul><li>Also Asset or Line Manager shall commit to the corrective action proposed for the close out of the non-compliances. </li></ul><ul><li>Complete Verification report </li></ul><ul><li>This shall comprise a word document summarizing the findings of the audit, the completed tracking matrices reflecting the verified compliance status and non-compliance resolution sheet. (Appendix 1) </li></ul>Steps involved in Conducting Reg. Compliance verification/ Audit.
    34. 34. <ul><li>Stating the details of the non-compliance as observed in the facilities visited, agreed corrective action and time lines for implementation of the corrective actions. </li></ul><ul><li>In summarizing the findings of the verification, all relevant information including results of past verification exercises should be stated to give an indication of trend. </li></ul><ul><li>Draft copies of the report shall be published for comments from the asset teams at least two weeks after the verification exercise while final copies shall be published maximum three weeks after the exercise. </li></ul>Steps involved in Conducting Reg. Compliance verification/ Audit Cont.
    35. 35. <ul><li>Corrective Action Tracking </li></ul><ul><li>All non-compliances and the agreed corrective actions and dates shall be entered into the SPDC Compliance Verification Resolution Form and duly endorsed by the Asset Owner or his representative (HSE Lead) and the Location Lead HSE Compliance or his representative (Compliance Advisor). This is the commitment document that all the non-compliances shall be addressed at the times specified by the action parties. </li></ul><ul><li>Asset Owners may include remarks to indicate possible constraints to closeout actions but both signatories must agree on this. </li></ul><ul><li>Teams shall avail the non-compliance items and the close out dates into the Fountain Impact database system for tracking. </li></ul>Steps involved in Conducting Reg. Compliance verification/ Audit Cont.
    36. 36. <ul><li>Compliance status Report </li></ul><ul><li>The Compliance Status report for the Company shall be published, for all verified Regulations, Half yearly by the HSE Compliance Team. The report will comprise of the compliance status from all the teams verified as at the time of report publication and the status of closeout actions. </li></ul><ul><li>It shall also include updates on Regulatory issues across the company and corporate actions on addressing some company-wide non-compliance issues. </li></ul><ul><li>This report will also form the basis of feedback from the Line teams. </li></ul>Steps involved in Conducting Reg. Compliance verification/ Audit Cont.
    37. 37. Adequate commitments and human resources are critical factors in the success of the internal Regulatory Compliance verification process. It is therefore essential that the regulatory compliance verifiers/auditors/inspectors receive as a minimum, appropriate training, either as auditors/ internal auditors or through a programme of shadowed and observed auditing/inspection under a lead auditor in line with EP2005-0180 and associated Work Instructions. A satisfactory completion of a minimum of 3 of these verification audits would guarantee confirmation as a competent compliance inspector by the HSE Manager. Competence Requirement for compliance inspectors
    38. 38. Application of Skills and Personal Judgment Unlike other types of audits where the auditor could use his judgment and audit skills in grey areas, statutory compliance audit is specific and only subject to legal / regulatory control. As such, witnessed evidence shall either be compliant or non-compliant. Where there is a disagreement between the Auditee and Auditor, the understanding of the Regulators shall apply. Steps involved in Conducting Reg. Compliance verification/ Audit Cont.
    39. 39. “ USE OF HSE REGULATORY TRACKING MATRIX” Objective <ul><li>To familiarize participants with the component and the use of HSE regulatory tracking Matrix </li></ul>
    40. 40. WHAT IS A TRACKING MATRIX ? <ul><li>HSE Regulatory tracking matrix is a tool used in tracking percentage compliance of a given team in respect of a particular regulation e.g Environmental Guidelines and Standard for the Petroleum Industries in Nigeria (EGASPIN), The Mineral Oil Safety Regulation (MOSR), Factories Acts, Petroleum Acts e.t.c. </li></ul><ul><li>The Tracking Matrix has three key columns, they are the Do , Have and Report columns. Each column is formatted and will automatically change when inputted with a C for complying or an NC for Not complying,while N/A for not applicable will not affect the percentage compliance result of the team. </li></ul>
    41. 41. The DO Column <ul><li>The Do column requires the team or individual to carryout a particular or set of action. </li></ul><ul><li>The following are examples of a Do statement from some applicable regulation </li></ul><ul><ul><li>Licencee/Leasee shall institute planned and integrated environmental management practices ( EGASPIN ) </li></ul></ul><ul><ul><li>Appoint, in writing, a person to be a manager who shall take continual charge of all the operations authorised by the licence or lease ( MOSR ) </li></ul></ul><ul><ul><li>Every industry shall install anti-pollution equipment for the detoxification of effluent and chemical discharges emanating from the Industry ( FMEnv ) </li></ul></ul><ul><ul><li>All agencies, institutions must apply in writing to the FEPA before embarking on a project, to enable an environment assessment to be carried out at an early stage ( EIA ) </li></ul></ul>
    42. 42. The Have Column <ul><li>The Have column requires the team or individual to possess or acquire a particular or set of things </li></ul><ul><li>The following are examples of a Have statement from some applicable regulation </li></ul><ul><ul><li>Licencee/operator shall have an environmental management system manual ( EGASPIN ) </li></ul></ul><ul><ul><li>The manager shall ensure that workers are provided with the appropriate hearing protection if noise levels are equal to or greater than 85 dBA for an 8 hour time weighted average TWA.( MOSR ) </li></ul></ul><ul><ul><li>No person or body corporate shall engage in the storage treatment and transportation of harmful toxic waste within Nigeria without a permit issued by the Agency.( FMEnv ) </li></ul></ul><ul><ul><li>A certificate will be issued by the relevant Agency after completion of an EIA.( EIA ) </li></ul></ul>
    43. 43. The Report Column. <ul><li>The Report column requires the team or individual to inform or notify the regulators of an activity or set of activities. </li></ul><ul><li>The following are examples of a Report statement from some applicable regulation </li></ul><ul><ul><li>All spillages of crude oil/chemical/oil products shall be reported to the Director of Petroleum Resources, in accordance with the oil spillage/notification reporting formats, A, B and C.( EGASPIN ) </li></ul></ul><ul><ul><li>Operators to make available to the DPR results of conducted Annual Audiometric test for personnel who work in high noise areas.( MOSR ) </li></ul></ul><ul><ul><li>Industries must inform Agency of toxic, hazardous and radioactive substances on their Premises, discharged during production.( FMEnv ) </li></ul></ul><ul><ul><li>Incase of a change in respect to the particulars set out in the application,the the occupier should inform the DOF in writing..( FA ) </li></ul></ul>
    44. 44. Example of a tracking Matrix
    45. 45. Calculation for Percentage Compliance with Formula: % Compliance = number of complied requirements X 100 Total number of applicable requirements