Integrated Pollution Prevention & Control Licence Review
Johnson & Johnson Vision Care Ireland
AAttttaacchhmmeenntt CC
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Attachment C: Management of the Installation C.1 Site Management & Control
The site organisational arrangements, EHS policy and Environmental Management Programme are outlined below:
C.1.1 Organisational Chart The organizational chart for the Vistakon Facility contained in the Vistakon Ireland Environmental
Systems manual can be seen in below:
Organisational Chart 2008
EHS SPECIALIST EHS SPECIALIST
EHS MANAGER
FACILITIES TEAMLEADER
SITE SECURITY
FACILITIES TECHNICIANS CAL/WR TECHNICIANS
FACILITIES ENGINEERS
LOGISTICS PERSONNELPUR/WH/SP
LOGISTICS DIRECTOR
HR SPECIALISTS
HR DIRECTOR
QUALITY TECHNICIANSQC/MICRO/CHEM
QUALITY TEAM LEADERS
QUALITY DIRECTOR
FINANCE TEAM
FINANCE DIRECTOR
TOOL ROOM TECHNICIANS
MET
ENGINEERING TEAM LEADERS
ENGINEERING DIRECTOR
PROCESS TECHNICIANS
OPERATIONS ENGINEERS
BUSINESS UNIT MANAGERS
OPERATIONS DIRECTOR
FACILITIES DIRECTOR
General Manager
VP WW OPERATIONS
VP WW SUPPLY CHAIN
Formatted
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C1.2 EHS Policy: The EHS policy is as follows:
EEnnvviirroonnmmeenntt,, HHeeaalltthh && SSaaffeettyy PPoolliiccyy
We are committed to protecting the health and safety of our employees, contractors and visitors and preserving our environment. It is our goal to provide an injury and illness free workplace,
prevent pollution and achieve healthy lifestyles. Environment, Health & Safety (EHS) is an operational function that impacts the productivity, quality and profitability of the organization. In
support of this commitment:
Health, safety and preserving the environment are the responsibilities of each employee. Senior Leaders will provide the vision, focus and resources to ensure that safe, healthy and
sustainable practices are central to all activities on site. Senior leaders will manage and monitor EHS efforts as they would any other operational
function. EHS objectives and targets will be set and reviewed for continuous improvement by reducing
the environmental, health and safety impacts of our processes and products. We are committed to operating in compliance with all applicable regulatory and J&J
Corporate EHS standards. Information instruction, training is provided to ensure all employees possess the knowledge and
skill required for the healthy and safe performance of their work with minimum environmental impact and to promote their involvement and accountability in EHS activities.
We strive to create products and processes that are inherently safe and that incorporate the principles of pollution prevention, waste minimization, energy efficiency and process safety.
We maintain and periodically test the Emergency Response Plan. We provide an occupational health service that includes physical and psychosocial health
needs such as; absence & disability management, employee assistance, health & wellness. We strive to ensure that the site’s environmental footprint is minimised by purchasing
sustainable resources and energy where practicable; We promote the use of the health & safety, environmental and energy management systems
by suppliers and contractors; Where accidents or incidents do occur; we take prompt corrective action, investigate root
causes, actively seek to prevent recurrences and disseminate experiences learned. We support EHS awareness and education based programs within the community.
We must consider EHS in every decision we make and in every activity we perform. We care about the health and safety of our fellow employees, their families, their communities, our customers, contractors and visitors. We operate in a manner, which minimises adverse impact on employees, local community and environment, utilising energy and other resources responsibly and efficiently.
Signed: _______________________________ Date : ____________________
GENERAL MANAGER
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C1.3 Environmental Management Programme:
ENVIRONMENTAL
MANAGEMENT
PROGRAMME
April 2009
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Table of Contents
1.0 Revision Record & Approval Signatories
2.0 Introduction
3.0 Control of the Environmental Management Programme
3.1 Administration of the Environmental Management Programme
3.2 Revision History
3.3 Change Description Log
4.0 Healthy Planet Goal Applicability Guide
5.0 Objectives and Targets
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1.0 Revision Record & Approval Signatories Revision Number : REVISION 5
Date : 20th April 2009
Prepared by: ___________________________
Anne Irwin
EHS Specalist Date: ____________________________
Reviewed by: ___________________________ Coleman Dillon
Senior EHS Specialist
Date: ____________________________ Approved by: ___________________________ Margaret Stokes
EHS Manager
Date: ____________________________
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2.0 Introduction 2.1 Environmental Site Review The site environmental review is carried out on an annual basis in accordance with the requirements of IN-IDP-0004. The purpose of the review is to identify the significant environmental aspects of our current and proposed activities, products or services and their impact on the environment.
2.1.1 All aspects are evaluated using the following criteria:
• Controls/detection • Frequency of occurrence • Cost of remediation • Severity of consequences • Legislative requirements • Corporate requirements
2.1.2 For each criteria, a rating of 1 -5 is used, with 5 being the most frequent or severe. The
significance of each impact is calculated and impacts with a score >1000 are considered significant.
2.1.3 The results of the annual Site Environmental Review may be included in the Annual Environmental Management Review as outlined in the Environmental Systems Manual. The reduction or elimination of these environmental Impacts identified as significant may become an environmental objective for inclusion in our Environmental Management Programme.
2.2 Environmental Management Programme
Vistakon Ireland’s Environmental Management Programme has been developed to achieve our objectives. The objectives have been deemed as significant from the Site Environmental Review Meeting and also the Healthy Planet 2010 Goals.
2.2.1 The Healthy Planet 2010 Goals is a set of goals that replace the Johnson & Johnson Next Generation Goals (NGG). These goals continue the commitment to the health and well being of the Earth. This world wide initiative engages every Johnson & Johnson employee, and goes beyond what is required by government and embraces our responsibilities to the global community as defined by the Johnson & Johnson Credo. The Johnson & Johnson Healthy Plant Goals are:
• Goal 1: Compliance • Goal 2: Environmental Literacy • Goal 3: Biodiversity • Goal 4 : Transparency • Goal 5: Product Stewardship • Goal 6 : Paper & Packaging • Goal 7: Carbon Dioxide Reduction • Goal 8: Fleet Efficiency • Goal 9: Water Use • Goal 10: Waste • Goal 11: External Manufacturers and suppliers.
Some of these are managed on a franchise basis and some are site specific.
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2.2.2 The designation of a responsible person(s) for the implementation of the each objective and target is assigned to the EHS Team and agreed with Senior Management.
2.2.3 Projects / methods by which the objectives and targets are to be achieved is the responsibility of the responsible person.
2.2.4 The time frame for achieving the objectives and for ongoing monitoring of progress, is monitored through Healthy Planet Meeting and the Environmental Management Review Meetings which are documented.
2.2.5 These objectives are reviewed and updated as required or on an annual basis in accordance with the requirements of IN-IDP-0005 (Procedure for the review of the Environmental Management System and is on the Agenda of the Environmental Management Review).
2.2.6 Progress of site specific goals is tracked in EDGE2, an Environmental Performance Report which records Healthy Planet Goal data for all Johnson & Johnson Facilities. This report is completed twice yearly by the EHS Specialist and is submitted to the WWEA.
3.0 Control of the Environmental Management Programme
3.1 Administration of the Environmental Manual
3.1.1 The Environmental Management Programme is a controlled document. 3.1.2 The overall preparation and update is the responsibility of the EHS
Specialist. 3.1.3 The review and approval of the Environmental Manual is the responsibility
of the EHS Manager. 3.1.4 The Environmental Management Programme is a unique document. It
does not have a document number, but has a sequential revision number.
3.1.5 All updates to the Environmental Management Programme are carried out in accordance with the requirements of Section 4.3. A history of changes to the Environmental Management Programme is maintained.
3.1.6 The Environmental Management Programme is controlled through the Environmental Documentation Control Function. The original copy of the Environmental Management Programme is held by the EHS Specialist and is available to all employees on the Intranet Safety & Environmental Section.
3.2 Revision History
3.2.1 All changes to the Environmental Management Programme will be
tracked on the Revision Log in Section 3.3. 3.2.2 The EHS Manager in accordance with the requirements of Section 4.1.3
must approve all changes. 3.2.3 Following approval, the updated Environmental Management
Programme will be issued and controlled as outlined in Section 4.1.
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3.3 Change Description Log
Revision
Change Description Originator Approval Date
Original
New Document to replace the existing Environmental Management Programme which is out of date.
A. Irwin/P. Moroney
12th July 2004
Revision 1
1. Modifications made to satisfy organisational changes and other changes to satisfy Maps on TRAC.
2. All changes are logged with the HR Administrator.
Anne Irwin/ Pearse Moroney
16th February 2005.
Revision 2
1. Modifications made to satisfy organisational changes and other changes.
2. All changes are logged with the HR Administrator.
Anne Irwin/ Pearse Moroney
12th July 2005.
Revision 3
All changes are logged with the HR Administrator. The changes are made as a result of the implementation of the Healthy Planet 2010 Goals and also the Implementation of the Objectives for 2006.
Anne Irwin/ Pearse Moroney
20th June 2006.
Revision 4
1). Modifications made to reflect organisational changes in the EH&S Dept. 2). Update the Objectives and Targets fro 2007. 3). All master changes logged with the EH&S Co-ordinator.
Anne Irwin/Gerard Lynn
27th July 2007.
Revision 5
1). Modifications made to reflect organisational changes in the EHS Dept. 2). Update the Objectives and Targets for 2009. 3). All master changes logged with the EHS Specialist.
Anne Irwin/ Margaret Stokes
20th April 2009
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4.0 Healthy Planet Goal Applicability Guide The following table indicates the applicability of the Healthy Planet 2010 Goals to the Vistakon Ireland site. The goals indicated with a circle are applicable to this site. Vistakon Ireland is included within the J&J Consumer group franchise: 2010 Goal Categories
Vistakon Ireland Site
Compliance
•
Environmental Literacy • Biodiversity
•
Transparency
•
Product Stewardship • Paper & Packaging
•
CO2 Reduction
•
Fleet Efficiency
•
Water Use
•
Waste
•
EM’s & Suppliers
•
5.0 Objectives and Targets 2009
The 2009 Objectives and targets are as follows:
Office paper Only
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EMP Objective Number: 1
Environmental Awareness of Suppliers & Contractors
Aspect No. 012 in the Site Environmental Review received a Rating of 5,625 in the Aspects & Impacts Meeting in 2008.
Target: Ensure that all Contractors and high-risk suppliers are fully
familiar with Johnson & Johnson Safety and Environmental requirements.
Rationale:
Company goals developed from Site Environmental Review, register of Aspects and Impacts.
Timeframe: Ongoing through 2009 - 2010 Measure: Zero incidents on-site caused by Contractors
Responsibility: Coleman Dillon Resources Required: EHS Resources Actions: Develop contractor management procedures to include
evaluation of potential environmental impacts and performance.
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EMP Objective Number: 2
Hazardous Waste Generation and Disposal
Aspect No. 006 in the Site Environmental Review received a Rating of 3,750 in the Aspects & Impacts Meeting in 2008.
Target: 10% Absolute Reduction by 2010, baseline 1990.
Rationale:
Company goals developed from Site Environmental Review, register of Aspects and Impacts.
Timeframe: Ongoing through 2006 - 2009 Measure: SRM in the UK are receiving our waste IPA and it is being recycled
and used in another process. Responsibility: Margaret Stokes Resources Required:
EHS Personnel
Actions: 1).Evaluate feasibility of on-site re-use and recovery of solvent
waste 2). Audit Hazardous Waste Facilities
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EMP Objective Number: 3
On Going Compliance with Effluent Licence Conditions
Aspect No. 001 in the Site Environmental Review received a Rating of 2,500 in the Aspects & Impacts Meeting in 2008.
Target: Zero non-compliances with Licence conditions Zero government-issued violations Zero accidental releases
Rationale:
Company goals developed from Site Environmental Review, register of Aspects and Impacts and the Healthy Planet 2010 Goal.
Timeframe: Ongoing through 2009 - 2010 Measure: Zero non-compliances with Licence conditions
Zero government-issued violations Zero accidental releases
Responsibility: John Magner/Margaret Stokes Resources Required:
Testing/Calibration and maintenance of Equipment to ensure that continue to stay in specification of the IPPC Licencing Requirements. New equipment will also be investigated.
Actions: Training on Licence Compliance is included as part of the Induction
Training for all J&J Employees. Training on licence compliance requirements for facilities personnel Annual Awareness Training for all employees Routine measurement and monitoring of environmental data
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EMP Objective Number: 4
Use, Handling & Storage of IPA
Aspect No. 015 in the Site Environmental Review received a Rating of 1,500 in the Aspects & Impacts Meeting in 2008.
Target: Continue to ensure that there are no incidents on site in
relation to chemical release to the Environment which would have a major impact on our Licence. There exists a potential for adverse environmental impact due to the misuse or spillage of IPA.
Rationale:
Company goals developed from Site Environmental Review, register of Aspects and Impacts.
Timeframe: Ongoing through 2009 - 2010. Measure: To ensure that there are no incidents in relation to IPA spills or
other in the facility. Responsibility: John Magner/Margaret Stokes Resources Required:
On going with the EH&S Team and ENVA Personnel on Site.
Actions: 1).Review the spill procedures for completeness and update
accordingly. 2). Ensure all personnel associated with this project have chemical awareness/psm training. 3). Review ERT team training and response procedures
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EMP Objective Number: 5
Non Hazardous Waste, Generation & Disposal
Aspect No. 003 in the Site Environmental Review received a Rating of 900 in the Aspects & Impacts Meeting in 2008.
Target: Best practice evaluation and continue to drive waste
minimisation programmes in the facility.
Rationale:
Company goals developed from Site Environmental Review, register of Aspects and Impacts and the Healthy Planet 2010 Goal.
Timeframe: Ongoing through 2009 - 2010. Measure: To ensure that we maintain and improve our recycling
Programmes. We are currently recycling @ 97% of all waste. Responsibility: Anne Irwin/John Magner Resources Required:
Full Time Greenstar Personnel and monthly inspections audits by EH&S.
Actions: 1). Update waste posters in the waste rooms to include all new
waste sources by July 2009 2). Plans will be implemented with Buckleys or Mr. Binman to recover at least 60% of waste currently going to landfill which should bring our recovery up to 98%. 4). Working will Waste Contractor Supervisor to implement new changes in relation to Canteen Segregation this will include Training in the coming months.
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EMP Objective Number: 6
Water Use & Consumption
Aspect No. 004 in the Site Environmental Review received a Rating of 600 in the Aspects & Impacts Meeting in 2008.
Target: 10% reduction by 2010, baseline 2005. Best Practices
evaluation.
We will continue to ensure that we can where possible minimise
the amount of Water used in Production and Support areas. Rationale:
Company goals developed from Site Environmental Review, register of Aspects and Impacts and the Healthy Planet 2010 Goal.
Timeframe: Ongoing through 2009 - 2010. Measure: To ensure that we can where possible minimise the amount of
Water used in Production and Support areas.
Responsibility: John Magner Resources Required:
On going with Facilities and Engineering & Operations Personnel
Actions: 1). On-going projects with the Facilities and Engineering Teams
to address water use and reduction plant wide and to minimize usage where possible. 2). Review of water usage in DI water production plant
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EMP Objective Number: 7
Energy Use and Conservation
Aspect No. 002 in the Site Environmental Review received a Rating of 100
in the Aspects & Impacts Meeting in 2008.
Target: To ensure that we can where possible minimise the amount of
Energy used in Production and Support areas.
7% CO2 Reduction by 2010 – baseline 1990. Rationale: Company goals developed from Site Environmental Review,
register of Aspects and Impacts and the Healthy Planet 2010
Goal. Timeframe: Ongoing through 2009 - 2010. Measure: To ensure that we can where possible minimise the amount of
Energy used in Production and Support areas. Responsibility: John Magner/Ross Fanning Resources Required:
On going with Facilities/Engineering Personnel
Actions: On going projects with the Facilities and Engineering Teams to
address energy usage and reduction plant wide. 1). Facilities and production investigations to identify options for energy reduction and implementation where feasible ( see Energy Audit Attachment No.4) 2). The Annual Energy Awareness Week
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EMP Objective Number: 8
Environmental Literacy
Target: Environmental Literacy training has been designed to increase
employees Environmental awareness and understanding of Vistakon’s Issues and Global Environmental Issues. The purpose of this Goal is to motivate our Employees to be environmentally passionate and to make choices and take actions that have an environmentally positive impacts.
Rationale:
Healthy Planet 2010 Goal-Company goal.
Timeframe: On going from 2006 - 2010 Measure: At least one literacy module offered per year. At least 80% of
employees engaged. Responsibility: Anne Irwin Resources Required:
Ongoing with the EH&S Department.
Actions: 1). EH&S Induction Training will continue to be delivered through
Induction Training which occurs on Day 1 of starting with the Company. The Module title for 2008 is called Biodiversity. 2)EH&S Competencies will be added to the TDT to reiterate Environmental literacy and the Notice Board and email will be used to communicate critical information also. 3). The Community Outreach Plan will be updated to include initiatives organized for 2009.. 4). The annual Energy Awareness Week in October will be used to promote Environmental Literacy plant wide.
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C.2 Environmental Management System (EMS) Indicate whether an Environmental Management System has been developed for the installation. If yes, specify which standard and include a copy of the accreditation certificate. The site first received ISO1400 accrediation in 1999.
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Certificate of Registration
ENVIRONMENTAL MANAGEMENT SYSTEM
This is to certify that:
Vistakon Johnson&Johnson Vision Care Ireland Limited National Technological Park Limerick Ireland
Holds Certificate No: EMS 45965
and operates an Environmental Management System which complies with the requirements of BS EN IS0 14001:2004 for the following scope:
The manufacture of disposable contact lens.
For and on behalf of BSI:
ana aging Director, BSI Management Systems (UK)
Originally registered: 0910611999 Latest Issue: 10/1012005
Page: 1 of 2
--0
ThiS cenificate was issued electionicaiiy and remains the property of BSI and is bound by the conditions of contract. ThiS certificate does not expire. An eiectronic certificate can be authenticated Printed copies can be vaiidated atwbsi-giobai.comiciient~irectory Management The British Standards institution is incorporated by Royai Charter. Management Systems (UK) Headquaiters: P.O. Box 9000, Miiloo Keynes MK14 6WT. Tei: 0845 080 9000
Systems
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Certificate No: EMS 45965
Location Registered Activities
Vistakon The manilfacture of disposable contact lens. Johnson &Johnson Vision Care Ireland Limited National Technological Park Limerick Ireland
Originally registered: 09/06/1999 Latest Issue: 10/10/2005
Page: 2 of 2
The British Standards Institution is incorporated by Royal Chaner Management Systems (UK) Headquarters P 0 Box '3000, Milton Keynes MK14 6 W . Tel:
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