Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 1 of 15 Document owner Sign Approved by Sign Effective date Revision history Revision Form # Effective date Description of amendments 0 DCF 1 First issue.
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 2 of 15 Table of contents Clause Title Page 1 Purpose and scope 3 2 Normative reference 3 3 Terms and definitions 3 4 Environmental, safety and health management system requirements 3 4.1 General requirements 3 4.2 Policy 3 4.3 Planning 4 4.4 Implementation and operation 6 4.5 Checking 11 4.6 Management review 14Note: The clause numbers above are parallel to the ISO 14001 and OHSAS 18001 Standards.
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 3 of 151 Purpose and scopeThis EHS Manual (M-444) describes the environmental, health and safety managementsystem (EHSMS) of AAA Company (AAA).AAA is engaged in the provision of XXXXXXXXXXXXXXXX. As such, the scope of theEHSMS encompasses related activities, products and services.The EHSMS has been established to a) eliminate or minimize risks to the environment, personnel and other interested parties who could be exposed to EHS aspects and hazards associated with AAA’s activities, products and services, b) assure AAA of its conformity with its stated EHS Policy (P-42), and c) demonstrate AAA’s conformity with the ISO 14001 and OHSAS 18001 Standards.2 Reference publicationsThese documents serve as references only and thus not auditable: a) ISO 14004, Environmental management systems -- General guidelines on principles, systems and support techniques, b) OHSAS 18002, Occupational health and safety management systems – Guidelines for the implementation of OHSAS 18001, and c) International Labour Organization: 2001, Guidelines on Occupational Health and Safety Management Systems (OSH-MS).3 Terms and definitionsFor the purposes of this document, the terms and definitions given in the ISO 14001 andOHSAS 18001 Standards apply, including a) AAA refers to AAA COMPANY, b) EHS refers to environmental, health and safety, c) Health and safety refers to occupational health and safety d) EHSMS refers to AAA’s environmental, health and safety management system, and e) EHS Manual refers to AAA’s Environmental, Health & Safety Manual.4 Environmental, safety and health management system requirements4.1 General requirements
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 4 of 15AAA has established, documented, implemented and maintained an EHSMS, and continuallystrives to improve its effectiveness in accordance with the requirements of the ISO 14001 andOHSAS 18001 Standards.4.2 EHS PolicyTop management has defined and authorized the EHS Policy (P-42) and has ensured that it: a) is appropriate to the nature and scale of the organization’s EHS risks, b) includes a commitment to prevention of pollution, injury and ill health and continual improvement in EHS management and performance, c) includes a commitment to at least comply with applicable legal requirements and with other requirements to which the organization subscribes that relate to its EHS risks, d) provides the framework for setting and reviewing EHS objectives, e) is documented, implemented and maintained, f) is communicated to all persons working under the control of the organization with the intent that they are made aware of their individual EHS obligations, g) is available to interested parties, and h) is reviewed periodically to ensure that it remains relevant and appropriate to the organization.4.3 Planning4.3.1 EHS aspects and hazard identification, risk assessment and determining controlsAAA has established, implemented and maintained the EHS Risk Control Procedure (PR-431)for the ongoing a) identification of environmental aspects of its activities, products and services within the defined scope of its EHSMS that it can control and influence taking into account planned or new developments, or new or modified activities, products and services, b) determination of those environmental aspects that have or can have significant impacts on the environment, and c) identification of occupational health and safety hazards, assessment of associated risks and determination of necessary controls.The methodology is defined with respect to its scope, nature and timing to ensure it isproactive rather than reactive, and provide for the identification of EHS aspects and hazards,prioritization and documentation of associated risks, and the application of controls, asappropriate.
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 5 of 15For the management of change, AAA identifies the EHS aspects and hazards and EHS risksassociated with changes in the organization, the EHSMS, or its activities, prior to theintroduction of such changes. AAA ensures that the results of these assessments areconsidered when determining controls.When determining controls, or considering changes to existing controls, consideration is givento eliminating and reducing the EHS risks according to the following strategies: a) elimination, b) substitution, c) engineering controls, d) signage/warnings and/or administrative controls, e) personal protective equipment.AAA documents and keeps the results of EHS aspects and hazards identification, riskassessments and determined controls up-to-date in the EHS Risk Control Register (R-431).AAA ensures that the EHS risks and determined controls are taken into account whenestablishing, implementing and maintaining its EHSMS.4.3.2 Legal and other requirementsAAA has established, implemented and maintained the EHS Legal Requirements Procedure(PR-432) for a) identifying and accessing the legal and other EHS requirements that are applicable to it, and b) determining how these requirements apply to its EHS risks.AAA has ensured that these applicable legal requirements and other requirements to whichthe organization subscribes are taken into account in establishing, implementing andmaintaining its EHSMS.As such, AAA maintains the EHS Legal Requirements Register (R-432) to document allapplicable legal and other requirements and keeps this information up-to-date.Applicable sections of the following statutes are documented:
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 6 of 15 a) Environmental Quality Act 1974, including its regulations, and b) Occupational Safety & Health Act 1994, including its regulations.AAA communicates relevant information on legal and other requirements to persons workingunder the control of the organization, and other relevant interested parties.4.3.3 Objectives, targets and programmesAAA has established, implemented and maintained EHS objectives, at relevant functions andlevels within the organization. These EHS objectives are documented in the EHS ObjectivesRegister (R-433).The objectives are measurable, where practicable, and consistent with the EHS Policy (P-42),including the commitments to the prevention of pollution, injury and ill health, to compliancewith applicable legal requirements and with other requirements to which the organizationsubscribes, and to continual improvement.When establishing and reviewing its objectives, AAA takes into account the legal requirementsand other requirements to which the organization subscribes, and its EHS risks.It also considers its technological options, its financial, operational and business requirements,and the views of relevant interested parties.AAA has established, implemented and maintained suitable programmes for achieving itsobjectives. The programmes include as a minimum: a) designation of responsibility and authority for achieving objectives at relevant functions and levels of the organization; and b) the means and time-frame by which the objectives are to be achieved.The programmes are reviewed at regular and planned intervals, and adjusted as necessary,to ensure that the objectives are achieved.The programmes are specified in the the EHS Objectives Register (R-433).4.4 Implementation and operation4.4.1 Resources, roles, responsibility, accountability and authority
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 7 of 15Top management takes ultimate responsibility for EHS and the EHSMS.Top management demonstrates its commitment by: a) ensuring the availability of resources essential to establish, implement, maintain and improve the EHSMS such as human resources and specialized skills, organizational infrastructure, technology and financial resources, and a) defining and communicating the EHS Key Personnel Register (R-441) which documents the assigned roles, allocated responsibilities and accountabilities, and delegated authorities, to facilitate effective EHS management.AAA has appointed a member of top management with specific responsibility for EHS,irrespective of other responsibilities, and with defined roles and authority for: a) ensuring that the EHSMS is established, implemented and maintained in accordance with the ISO 14001 and OHSAS 18001 Standards, and b) ensuring that reports on the performance of the EHSMS are presented to top management for review and used as a basis for improvement of the EHSMS.The identity of the top management appointee is made available to all persons working underits control.An EHSMS Committee has been established to assist the Management Appointee in themanagement of the EHSMS. Members of this committee include all Department Managersand every meetng is chaired by the Management Appointee.All those with management responsibility demonstrate their commitment to the continualimprovement of EHS performance.AAA ensures that persons in the workplace take responsibility for aspects of EHS over whichthey have control, including adherence to the organization’s applicable EHS requirements.4.4.2 Competence, training and awarenessAAA ensures that any persons under its control performing tasks that can impact on EHS arecompetent on the basis of appropriate education, training or experience, and retainsassociated records.
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 8 of 15AAA identifies training needs associated with its EHS risks and its EHSMS. It provides trainingor take other action to meet these needs, evaluate the effectiveness of the training or actiontaken, and retain associated records.AAA has established, implemented and maintained the EHS Competence, Training &Awareness Procedure (PR-442) to make persons working under its control aware of: a) the EHS consequences, actual or potential, of their work activities, their behaviour, and the EHS benefits of improved personal performance, b) their roles and responsibilities and importance in achieving conformity to the EHS policy and procedures and to the requirements of the EHSMS, including emergency preparedness and response requirements (see 4.4.7), and c) the potential consequences of departure from specified procedures.The procedure takes into account differing levels of responsibility, ability, language skills,literacy and risk.4.4.3 Communication, participation and consultation188.8.131.52 CommunicationWith regard to its EHS risks and EHSMS, AAA has established, implemented and maintainedthe EHS Communication, Participation & Consultation Procedure (PR-443) for: a) internal communication among the various levels and functions of the organization, b) communication with contractors and other visitors to the workplace, and c) receiving, documenting and responding to relevant communications from external interested parties.184.108.40.206 Participation and consultationThe EHS Communication, Participation & Consultation Procedure (PR-443) also specifies: a) the participation of workers by their appropriate involvement in EHS risk identification, risk assessments and determination of controls, appropriate involvement in incident investigation, involvement in the development and review of EHS policies and objectives, consultation where there are any changes that affect their EHS and representation on EHS matters,
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 9 of 15 b) that workers are informed about their participation arrangements, including who is their representative(s) on EHS matters, and c) consultation with contractors where there are changes that affect their EHS.AAA ensures that, when appropriate, relevant external interested parties are consulted aboutpertinent EHS matters.4.4.4 DocumentationThe EHSMS documentation includes: a) EHS Policy (P-42), b) EHS Objectives Register (R-433), c) EHS Manual (M-444) which describes the scope, main elements, their interaction, and reference to related documents of the EHSMS, d) documents, including records, required by the ISO 14001 and OHSAS 18001 Standards, and e) documents, including records, determined by AAA to be necessary to ensure the effective planning, operation and control of processes that relate to the management of its EHS risks.The EHS documentation is proportional to the level of complexity and EHS risks concerned,and is kept to the minimum required for effectiveness and efficiency.4.4.5 Control of documentsDocuments required by the EHSMS are controlled and registered in the EHS DocumentsRegister (R-445) and EHS External Documents Register (R-445A) respectively.AAA has established, implemented and maintained the Control of Documents Procedure (PR-445) to: a) approve documents for adequacy prior to issue, b) review and update as necessary and re-approve documents, c) ensure that changes and the current revision status of documents are identified, d) ensure that relevant versions of applicable documents are available at points of use, e) ensure that documents remain legible and readily identifiable,
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 10 of 15 f) ensure that documents of external origin determined by the organization to be necessary for the planning and operation of the EHSMS are identified and their distribution controlled, and g) prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose.4.4.6 Operational controlAAA has established the EHS Operational Control Plan (PL-446) to document and controlthose operations and activities that are associated with the identified EHS aspects andhazards. This includes the management of change (see 4.3.1).For those operations and activities, AAA implements and maintains: a) operational controls, as applicable to AAA and its activities where the organization has integrated those operational controls into its overall EHSMS, b) controls related to purchased goods, equipment and services including their communication to the suppliers and contractors, c) controls related to contractors and other visitors to the workplace, f) documented procedures, to cover situations where their absence could lead to deviations from the EHS Policy (P-42) and the objectives, and d) stipulated operating criteria where their absence could lead to deviations from the EHS Policy (P-42) and objectives.4.4.7 Emergency preparedness and responseAAA has established, implemented and maintained the Emergency, Preparedness &Response Procedure (PR-447) to a) identify the potential for emergency situations, and b) respond to such emergency situations.AAA responds to actual emergency situations and prevents or mitigates associated adverseEHS consequences.In planning its emergency response, AAA takes account of the needs of relevant interestedparties, e.g. emergency services and neighbours.
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 11 of 15AAA periodically tests this procedure, where practicable, involving relevant interested partiesas appropriate.AAA periodically reviews and, where necessary, revises its emergency preparedness andresponse procedure, in particular, after periodical testing and after the occurrence ofemergency situations (see 4.5.3).4.5 Checking4.5.1 Performance measurement and monitoringAAA has established, implemented and maintained the EHS Performance Monitoring &Measurement Procedure (PR-451) to monitor and measure EHS performance on a regularbasis.This procedure provides for: a) both qualitative and quantitative measures, appropriate to the needs of the organization, b) monitoring of the extent to which the organization’s EHS objectives are met, c) monitoring the effectiveness of EHS controls, d) proactive measures of performance that monitor conformance with the EHS programmes, controls and operational criteria, e) reactive measures of performance that monitor environmental impacts, ill health, incidents (including accidents, near-misses, etc.), and other historical evidence of deficient EHS performance, f) recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective action and preventive action analysis, and g) the control of calibration and maintenance processes of monitoring and measuring equipment and the retention of associated records.4.5.2 Evaluation of complianceConsistent with its commitment to compliance (see 4.2c), the EHS Legal RequirementsProcedure (PR-432) specifies the process for periodically evaluating compliance withapplicable legal and other requirements to which it subscribes (see 4.3.2) and keeps recordsof the results of these periodic evaluations.4.5.3 Incident investigation, nonconformity, corrective action and preventive action
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 12 of 220.127.116.11 Incident investigationAAA has established, implemented and maintained the EHS Incident Investigation Procedure(PR-4531) to record, investigate and analyse incidents in order to: a) determine underlying EHS deficiencies and other factors that might be causing or contributing to the occurrence of incidents, b) identify the need for corrective action, c) identify opportunities for preventive action, d) identify opportunities for continual improvement, and e) communicate the results of such investigations.The investigations are performed in a timely manner. Any identified need for corrective actionor opportunities for preventive action are dealt with in accordance with the relevant parts of18.104.22.168.The results of incident investigations are documented and maintained.22.214.171.124 Nonconformity, corrective action and preventive actionAAA has established, implemented and maintained the Corrective & Preventive ActionProcedure (PR-4532) for dealing with actual and potential nonconformities and for takingcorrective action and preventive action.The procedure defines requirements for: a) identifying and correcting nonconformities and taking actions to mitigate their EHS consequences, b) investigating nonconformities, determining their causes and taking actions in order to avoid their recurrence, c) evaluating the need for actions to prevent nonconformities and implementing appropriate actions designed to avoid their occurrence, d) recording and communicating the results of corrective actions and preventive actions taken, and e) reviewing the effectiveness of corrective actions and preventive actions taken.
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 13 of 15Where the corrective action and preventive action identifies new or changed EHS aspects andhazards or the need for new or changed controls, the procedure requires that the proposedactions are taken through a risk assessment prior to implementation.Any corrective action or preventive action taken to eliminate the causes of actual and potentialnonconformities are appropriate to the magnitude of problems and commensurate with theEHS risks encountered.AAA has ensured that any necessary changes arising from corrective action and preventiveaction are made to the EHSMS documentation.4.5.4 Control of recordsAAA has established and maintained records as necessary to demonstrate conformity to therequirements of its EHSMS and of the ISO 14001 and OHSAS 18001 Standards, and theresults achieved.AAA has established, implemented and maintained the Control of Records Procedure (PR-454) for the identification, storage, protection, retrieval, retention and disposal of records.Records are ensured to remain legible, identifiable and traceable.All records are registered in the EHS Records Register (R-454).4.5.5 Internal auditAAA ensures that internal audits of the EHSMS are conducted at planned intervals to: a) determine whether the EHSMS: 1) conforms to planned arrangements for EHSMS, including the requirements of the ISO 14001 and OHSAS 18001 Standards, 2) has been properly implemented and is maintained; and 3) is effective in meeting the organization’s policy and objectives; b) provide information on the results of audits to management.
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 14 of 15Audit programmes are planned, established, implemented and maintained by theorganization, based on the results of risk assessments of the organization’s activities, and theresults of previous audits.The Internal Audit Procedure (PE-455) has been established, implemented and maintainedto address: a) the responsibilities, competencies, and requirements for planning and conducting audits, reporting results and retaining associated records; and b) the determination of audit criteria, scope, frequency and methods.Selection of auditors and conduct of audits ensures objectivity and the impartiality of the auditprocess.4.6 Management reviewTop management reviews the organization’s EHSMS, at planned intervals, to ensure itscontinuing suitability, adequacy and effectiveness.The reviews include assessing opportunities for improvement and the need for changes to theEHSMS, including the EHS Policy (P-42) and EHS objectives.The Management Appointee provides the following inputs: a) results of internal audits and evaluations of compliance with applicable legal requirements and with other requirements to which the organization subscribes, b) the results of participation and consultation, c) relevant communications from external interested parties, including complaints, d) EHS performance of the organization, e) the extent to which objectives have been met, f) status of incident investigations, corrective actions and preventive actions, g) follow-up actions from previous management reviews, h) changing circumstances, including developments in legal and other requirements related to EHS, and i) recommendations for improvement.The outputs from management reviews are consistent with the AAA’s commitment to continualimprovement and include any decisions and actions related to possible changes to:
Environmental, Health & Safety Manual AAA CompanyDocument code: M-444 Revision: 0 Page 15 of 15 a) EHS performance, b) EHS Policy (P-42) and objectives, c) resources, and d) other elements of the EHSMS.Relevant outputs from management reviews are made available for communication andconsultation (see 4.4.3).Records of the management reviews are retained.