Procedure for Incidents Investigation, Non-Conformity, and Corrective Action

1.0 PURPOSE:

 To establish, implement and maintain a procedure for:-

  • Handling and Investigating the Non-Conformances.
  • Taking actions to mitigate any Impacts/Risks caused and initiating, completing Corrective Action.
  • Defining responsibility and authority for the handling and investigating non-conformances.

2.0 SCOPE:

 It encompasses all the Activities, Processes Products & Services covered under EHS Management System.

3.0 RESPONSIBILITY:

 Dept. Heads concerned are responsible for Monitoring, Investigating Non-Conformance and taking Corrective & Preventive actions in their particular area.

4.0 PROCEDURE :

4.1 The non-conformance shall be identified as –

  • Deviations from the documented procedure/instructions not followed.
  • Unsafe practices / unsafe conditions.
  • Accidental emissions / discharges.
  • Deviation from the norms / specified limits.
  • Spillage / Leakage / Emission / Accident / Incident due to improper handling / improper maintenance / deviation from operational control procedures and documented procedures.
  • Any incident /accident having a significant impact/risk on the environment, or health or safety of persons.
  • Noncompliance to applicable legal requirements
  • Improper handling of hazardous materials/waste
  • Deviation from following the specified OCP’s /ERP
  • Deviation from the specification mentioned in the operation control procedure

4.2 Respective Team Members shall identify, record non-conformances, incidents and shall take appropriate actions through investigation & analysis.

4.3 Respective Team Members shall identify non-conformances; incidents periodically in the Environmental Incident Register (EHS-RG-05) and Incidents such as Near Misses/ Accidents are recorded in Incident report (EHS-F-08) accordingly and shall inform the concerned Dept Head to take appropriate actions.

4.4 Concerned HOD / his designated officer shall review/investigate the non-conformances, incidents and decide about the action to be initiated to mitigate the immediate impact.

4.5 Initiating corrective and preventive actions as detailed in the subsequent steps shall control the non-conformance identified.

4.6 Respective Dept Heads shall investigate the non-conformance by involving concerned workers/employees and details of the investigation are analyzed & recorded.

4.7 The Procedure for Corrective & Preventive Action is designed to ensure that appropriate Corrective & Preventive Actions are initiated based on the inputs from the following as appropriate:

  • Identified Non-Conformance, incidents
  • Internal / External EOHS Audit Results.
  • Emergency Situations

4.8 The concerned Dept Heads shall analyze the cause of the Non-Conformance and decide the Corrective & Preventive action required to eliminate the cause of actual and potential Non-Conformities.

4.9 The steps involved in initiating Corrective Action shall be –

  • Investigate the cause of Non-Conformance
  • Recording results of the investigation
  • Determination of Corrective Actions needed to eliminate the cause of Non-Conformance.
  • Ensure that the Corrective Actions are effective.

4.10 The Steps involved in Preventive action shall be –

  • Analyze all Processes to eliminate potential causes of Non-Conformances
  • Initiate Preventive Actions
  • Ensure that the Preventive Actions are effective.

4.11 The corrective and Preventive actions shall be taken appropriate to the magnitude of the problem and commensurate with the Environmental impact / OH&S risk encountered.

4.12 The respective Dept Heads along with the concerned worker/employee shall investigate the Non- Conformance.

4.13 EHS MR / Dept HOD’s shall verify the Corrective Action and shall also decide and update the change in any Operational Control Procedure / Work Instruction if necessary, as per the procedure for Document Control.

5.0 DOCUMENT / RECORD REFERENCE:

S.No. Document /Record Description Reference No.
1 Environmental Incident register EOHS-RG-05
2 Incident report EOHS-F-08
3 Work Permit EOHS-F-09

 

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