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 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 the 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