Procedure for Communication, Participation and Consultantation

1.0 PURPOSE:

To establish, implement & maintain a Procedure for Communication, participation, and consultation with regard to EHS Aspects / Hazards and Environmental, Occupational Health & Safety Management System.

2.0 SCOPE:

This procedure is applicable to the Internal and External Communication and consultation with interested parties for the Activities, Processes, Products & Services of XXX covered under Environmental, Occupational Health & Safety Management System.

3.0 RESPONSIBILITY: As defined in the table below.

4.0 DEFINITION:

4.1 Communication: It is the process of meaningful interaction among persons of an organization & external interested parties related to the EHS Management System.

5.0 PROCEDURE:

5.1 The Communication with Internal and External Agencies shall be done in order to ensure that:

  1. Internal functions at various levels are aware of the EHS Management System including the Significant Aspects / Hazards in their working area.
  2. The Communication from Interested Parties is received, documented and responded to the concerned.
  3. Processes for Communication with External Interested Parties on Significant Environmental Aspects/ hazards are considered.

5.2 The decisions taken regarding the concerned EHS Issues raised by any of the Interested Parties shall be routed through EHS MR.

5.3 The following table shows the various methods by which the Internal and external communication is established and the responsibility for the same.

5.3.1 INTERNAL COMMUNICATION

S.No. Topic For

Communication

Personnel To Be

Communicated

Resp. For Communication Mode Of

Communication

1. Awareness on the purpose of EHS Management System

All Employees

EHS MR & CFT Notice Board & Training Programme
2. EHS Policy All Employees EHS MR,  Dept Head Poster, Cards, Display boards & Training
3.

Role & Responsibility

Concerned Employees Respective Head of the Departments & HR Work Instruction / Procedures
4. Objectives And Targets All employees Respective Head of  the Departments Group Discussion,

Management

Review Meeting, Posters

5.

 

EHS Issues

Concerned Div. Heads EHS MR Emails, Minutes of Meetings,  Notes

Presentation.

6. Legal and other regulatory requirements. Concerned Employees

Legal Team

Mail mentioning legal requirement, Minute of Meeting.
7. EHS Performance Management Review Committee EHS MR Management Review Meeting

5.3.2 EXTERNAL COMMUNICATION

S.No. Interested Party Topic For

Communication

Mode Of Communication Resp. of Receiving, Recording and Communicating
1. Customer Any relevant Information as required by the Customer Verbal/ Letter/ emails Marketing
2. Local Community Any EHS Concerns raised Verbal / Letter/ emails HR
3. Supplier Request for improving Environmental & Safety Protection.

Any Other Issues  raised

Significant Impacts / Risks from their operations.

Letter/ emails Purchase
4. Visitors / Contractor’s Request for improving Environmental Protection

Any Other Issues raised.

Significant Impacts / Risks from their operations.

Verbal/ Letter / Notice board/emails Concern HOD’s
5. Banks & Insurers Relevant Information as required Letter/emails  

Finance

 

6. Media Initiatives taken by Organization & Subsequent Development Press-Release, Interviews, Presentation at Seminar/websites  

Director

7. Regulators (Govt. Authorities, Ministries) a) Response to Show-Cause

b) Consents

 

Letter/emails

 

HR

5.4 Management shall decide for external communication on following points through Management Review meeting if asked for.

  • Significant Environmental Aspects / Risks
  • EHS Performance.

EHS MR shall record the decision taken in minutes of the meeting. Management of XXX has decided not to communicate its Significant Environmental aspects to external interested parties.

5.5 EHS Policy shall be circulated to all suppliers to generate awareness about Environment & Safety. The key suppliers shall be included in EHS Awareness training to make them aware of Significant Impacts / Risks from their operations and to exercise control over them.

5.6 Internal Communication effectively established between the various levels of the Organization (i.e., Top down, bottom up and Horizontal communication channels) concerned department heads to their employees and to express their concerns/suggestions of employees, the suggestion box is made available at the factory.

5.7 EHS Policy is made available at main the gate for Visitors / Security. Any Concerns from Interested Parties shall be recorded in the Concerns/suggestions from interested party feedback form (EHS-F-03).

5.8 Concerns if any, raised by external interested parties are communicated through the proper channel through HR. Details of External communication with External parties are recorded by HR/Security. Details shall be recorded in the External Communication register (EHS-RG-04).

5.9 Awareness shall be given to the Security about the importance and purpose of the EHS Management System, including Awareness on Environmental Policy and communication.

5.10 Participation and Consultation

5.10.1 Participation:

 Employees / Workers are involved in Aspect and Impact analysis, hazard risk identification & risk assessment also the identification of necessary control measures. Employees are also involved in the development of EHS objectives. During risk assessment & determination of control measures due consideration is given to identify EHS objectives. Workers are involved in incident investigation & details of investigations are recorded in the incident register.

5.10.2 Consultation on Health and Safety matters:

Safety Officer conducts quarterly safety committee meeting with employee representatives, EHS MR & CFT members. The agenda for the meeting includes –

  1. Development and review of systems to manage OH & S risks.
  2. Any change that affects workplace safety and health.
  3. Any other health and safety matters

Input for the meeting also includes feedback on concerns from interested parties. The decisions and further actions are recorded by HR and circulated to the concerned personnel for action. HR Maintains minutes of safety committees in QSA-FR-05

6.0 Document / Record reference:

S. No. Document /Record Description Reference No.
01. Concerns/suggestions from interested parties EHS-F-03
02. External communication register EHS-RG-04
03. Internal Feedback form EHS-F-05
03. Minutes of  Meeting (Safety Committee) QSA-FR-05

 

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