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ENVIRONM ENTAL M ANAGEM ENT MANUALDocument Level – I

Revision : 00

Issue: A

EFFECTIVE DATE : 05.11.2004

Designation of Holder : Management Representative

Total Pages : 46

Controlled / Uncontrolled Copy : Controlled copy

ENVIRONMENTAL MANAGEMENT SYSTEM – ISO 14001:1996

RUSHIL INDUSTRIES LTD.Plot no. 54, Ship Breaking Yard, Alang

P.O. Manar- 364150 (Gujarat.)!!!! (02842)-235466/ 235506 FAX: (0278)-2515676 

E-mail: [email protected]

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

EM-00  Environmental Manual[Clause no. 4.4.5 ISO 14001 : 1996] 

Prepared by

Plot Manager

Released by

Plot Manager Doc. Status

Authorized By

DirectorPage 2 of 46 

FM-MGT-04 EMM-Document Control RecordClause No.

0.1 Title : ENVIRONMENTAL MANAGEMENT MANUAL

0.2 Document no. : EM-00 ISO 14001 : 1996

0.3 Issue to :

Copyno.

Name of the copy holder Designation Department

01 Management Representative Environment &

Safety Supervisor

Environment

& Safety

0.4 Revision Record

Date ofRevision

Revisionno &page

Revision Details Approvedby / date

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EM-00  Table of Contents

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DirectorPage 3 of 46 

Description of Clauses – ISO 14001:1996 EMS ISOClause

no.

Page no.

Cover page 1

EMM- Document Control Record 2

Table of contents 3,4

Letter of Authorization --- 5

Scope of our environment management system --- 6-10

Organization Fact sheet --- 11-13

Regulatory Approvals 4.3.2 14

Organization chart 4.4.1 15

Responsibility & Authority 4.4.1 16,17

ISO 14001 :1996 Clause-wise Responsibility Matrix --- 18

Compatibility with other management systems --- 19

Scope 1 20

Normative references 2 21

Definitions 3 22,23

General requirements 4.1 24,25

Environmental policy 4.2 26,27

Planning 4.3 28-31

−  Environmental aspects 4.3.1 28

−  Legal and other requirements 4.3.2 29

−  Objectives and targets 4.3.3 30

−  Environmental management programme(s) 4.3.4 31

Implementation and operation 4.4 32-40

−  Structure and responsibility 4.4.1 32

−  Training, awareness and competence 4.4.2 33,34

−  Communication 4.4.3 35

Environmental management system documentation 4.4.4 36-40

−  Document control 4.4.5 36,37

−  Operational control 4.4.6 38,39

−  Emergency preparedness and response 4.4.7 40

Checking and corrective action 4.5 41-45

−  Measurement and monitoring 4.5.1 41,42

−  Non-conformance and corrective andpreventive action

4.5.2 43

−  Control of Records 4.5.3 44

−  Environmental management system audit 4.5.4 45

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EM-00  Table of Contents

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Management review 4.6 46

 Annexure1- Ship breaking processes

 Annexure 2-Copy of Regulatory Approvals

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EM-00  Letter of Authorization

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DirectorPage 5 of 46 

This evidence of authorization for approval of the contents of the EnvironmentalManagement Manual by Director is as follows:

I myself have studied, reviewed & finally approved contents of this environment manual which isprepared for meeting all requirements of ISO 14001 : 1996 in tandem with legal and otherrequirements, which is implemented & continually improved in RUSHIL INDUSTRIES LTD., Alang,Dist: Bhavnagar

Place: Alang, Dist: BhavnagarDate: 05.11.2004 Director

[This manual may only be reproduced with written permission from Management Representative]

 

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EM-00  Scope of our EMS

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INTRODUCTION

The Director of M/s RUSHIL INDUSTRIES LTD. has taken a strategic decisionto adopt ISO 14001: 1996 Environmental Management System in theorganization. The design and implementation of our Environmental managementsystem is influenced by application of relevant and specific InternationalStandards i.e ISO 14001 : 1996, statutory and regulatory guidelines by GMB andother legal requirements, particular objectives of the processes employed andthe size and structure of our organization.

This Environmental Management Manual may be used for reference by internaland external parties, including certification bodies, to assess the organization’sability to meet legal, regulatory & organization’s own requirements.

Scope of our environment management system includes “ Breaking of ships, sale

of steel and other materials, components, machinery derived from ships.” 

 APPLICABLE CLAUSES OF ENVIRONMENTAL MANAGEMENTSYSTEM:

 As described in Clause 1 i.e. Scope of the Standard, All the requirements of thisstandard are incorporated in this environment management system, Ourorganization has established documented, implemented and maintained anamalgamated environmental management system and continually improves itseffectiveness in accordance with the requirements of relevant and specific legalrequirements and International standards as referred in Introduction above.

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EM-00  Scope of our EMS

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STRUCTURE & FORMAT

It conveys accurately, completely and concisely the environment policy,quantified objectives with targets for accomplishments and governingdocumentation processes and procedures of the organization.

We have adapted a method of applying a key to various sections of thisenvironment manual and the environment elements of the governingenvironment management system standard for assuring that the subject matter isadequately addressed and located.

CONTENTS

This Environment Manual consists of, or refers to, the documented environmentmanagement system procedures and processes intended for overall planningand administration of activities that have impact on environment within ourorganization.

This Environment Manual covers all the applicable elements of environmentmanagement system standard i.e. ISO 14001 :1996. It describes to the degree ofdetail required for adequate control of the activities concerned, theresponsibilities, authorities and interrelationships of the personnel. These are thepersonnel who manage, perform, verify or review (a) work affecting environment(b) how the different activities are to be performed (c) the documents to be used

and (d) the controls to be applied.

FINAL REVIEW AND APPROVAL:

Prior to issuing the manual, the document was reviewed by responsibleindividuals to ensure clarity, accuracy, suitability and proper structure. Theintended users also had the opportunity to assess and comment on the usabilityof the document.

The Director who is responsible for implementation has approved thisenvironment manual and then released. Each copy bears evidence of thisrelease authorization.

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EM-00  Scope of our EMS

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DISTRIBUTION OF THE MANUAL :

The method of distribution of the authorized manual, whether in total or bysections, provides assurance that all users have access.

Proper distribution and control is being aided, for example, by serialization ofcopies of recipients.

Our top management has ensured that individuals are familiar with thosecontents of the manual appropriate to each user within the organization.

MANOEUVRABILITY:

a) Environment Manual is revised whenever changes are made in thestipulated policies and is regularly maintained by MR. The Director & MRcarry out the review of the EM mutually. However, the MR is authorized tomake changes in the contents of the EM with the approval of the Director.

b) Following officer is officially identified to assist MR and discharge therequired responsibilities in absence of MR.

[1] Mr. Nirav D. Motiwala (Plot Manager)

c) In case of special circumstances, like absence of Environment and SafetySupervisor, the employee can directly approach Plot Manager with a

 justification for the changes to be made.

d) In case of absenteeism at any level, the responsibility goes downward &authority upward.

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EM-00  Scope of our EMS

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INCORPORATION OF CHANGES:

 A method of providing for the initiation, development, review, control andincorporation of changes to the manual is provided.

This task is assigned to an appropriate document control function, which ishandled by MR. The same review and approval process used in developing thebasic manual is being applied when processing the changes.

Issue and change control:

Document issue and change controls are established to ensure that the contentof the manual is properly authorized.

"  The authorized content is readily identifiable. Various methods areconsidered for facilitating the physical process of making changes.

"  To ensure that each manual is kept up to date, a method is determined toassure that all changes are received by each manual holder andincorporated in to copy of each manual. A separate revision-status page isused to assure the users that they have the authorized manual/copy ofprocedures.

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EM-00  ORGANIZATION FACT SHEET

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Organization : RUSHIL INDUSTRIES LTD.

Established in : 1989

Nature of ownership : LIMITED

Plot Manager :

Environment and safety :Supervisor

Total handled DWT till now :

Total ships broken till now :

Major fire occurrences :

Occurred during :

Fatal casualties till now :

Occurred during :

Infrastructure

Plot area :

Wastage storage space :

Water tank capacity :

Number of gas meters & oxygen :meters

Other resource details :

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EM-00  ORGANIZATION FACT SHEET

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SET- UP OF THE ORGANIZATION

•  Organization hierarchy

The organization is led by Director , __________________ having more than ____ yearsof experience in the industry .The introductory details like name, experience &designation of key members are as under :

Sr.No.

NameQualification /Experience Designation

List of Resources available :

Steel cutting guns :

Gas pipe in meters :

Cranes :

Winch :

LPG cylinders :

Oxygen cylinders :

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EM-00  ORGANIZATION FACT SHEET

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Environment and safety equipment

Wastage storage space :

Buckets for waste collection :

Fire extinguishers :

CO2 Foam :

CO2 Powder :

Fire fighting suits :

Oxygen masks :

Sand buckets :

Limit of insurance taken :

Fire fighting pumps :

Helmets :

 Anti-glare glasses :

Safety belts :

Mask for steel cutting :

 Aprons / Boiler suits for steel cutting :

Hand gloves :

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EM-00  REGULATORY APPROVALS

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#  List of regulatory authorities :

1. Gujarat Maritime Board Alang Gujarat2. Department of Explosives Baroda Gujarat3. Gujarat Pollution Control Board Baroda Gujarat4. Department of Indian Customs Alang Gujarat5. Ministry of Environment & Forest New Delhi6. Factories Inspectorate Alang Gujarat

Letter of approvals received from regulatory authorities :

Srno. Title of letter /certificate

Ref no. Date

01 License to operate fromGMB

02 Health certificate File

03 GPCB hazardousstorage authorization.

04 LPG Storage License

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EM-00  ORGANIZATION STRUCTURE

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Our organization follows a lean hierarchy in the following manner.

Director 

Plot Manager 

Environment and Safety Supervisor 

(Management Representative)

Field Supervisor  Ship Supervisor Crane and Winch

Operators

Gas cutters & helpersGas cutters & helpers

Workshop In-charge

Organization structure

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EM-00  RESPONSIBILITY AND AUTHORITY

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MANAGEMENT REVIEW MEETINGS:

To ensure the continuing suitability, adequacy and effectiveness of theorganization’s environment management system, the top management hasadapted process of conducting reviews every 6 months.

RESPONSIBILITY & AUTHORITY:

Persons familiar with good environment practices, procedures, objectives andassessment of the results, provide supervision.

The responsibility, authority and the inter-relation of personnel who manage,perform and verify work having significant environment impacts is defined anddocumented, particularly for personnel who need the organizational freedom andauthority to;

a) Initiate action to prevent the occurrence of any nonconformities relating tothe environment , process and environment management system.

b) Identify and record any problems relating to the environment , process andenvironment management system.

c) Initiate, recommend or provide solutions through designated channels.d) Verify the implementation of preventive and corrective actionse) Control further continuation of nonconforming activity until the deficiency

or unsatisfactory condition has been corrected.

We hereby declare and ensure that our management and personnel are freefrom any undue internal and external commercial, financial and other pressuresand influences that may adversely affect the environment of their work.

Sr.No.

Responsibility Authority Interfacing with

01 Director-  Introduction review and continual

improvement of modern environmentmanagement system ISO 14001 :1996and overall environment management

-  Marketing Function, Resources

management-  Encourage training for all employees-  Decision on environment aspects and

impacts , Environment Manual review-  Review of performance of significant

environment aspects and impacts

He enjoys fullfreedom to takeindependentdecisions in theenvironment al

interests oforganization

Plot Manager

Environment andSafety Supervisor

GMB

State and Centralgovernmentauthorities

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EM-00  RESPONSIBILITY AND AUTHORITY

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-  Planning, Environment ManagementProgram reporting

-  Review of Legal requirements-  External communication

-  Management Reviews 

GPCB

Dept of explosives

Customs department 

02 Plot Manager-  Dispatch management-  Plot management including steel cutting,

pumping out of oil, beaching, crane andwinch operations.

-  Waste management planning-  Internal audits, Corrective and preventive

action-  Implementation of regulations from

Regulatory Authorities

- Ensure that operations are controlledaccording to legal requirements 

-  Ensure that all documents are updatedtimely, Environment procedure review 

-  Implement actions from managementreview 

-   Achievement of environment objectivesand targets

Enjoys full freedomfor discharging hisduties.

Implement policies atplot as perrequirements andpractical situations

Meeting all

requirements of legal& regulatoryauthorities.

TSDF Site

Environment andSafety Supervisor

Gas cutters andhelpers

03 Environment & Safety Supervisor (ESS) -Management Representative

4 -  Ensure that all environment practices arefollowed by steel cutters, helpers, craneoperators and winch operators

-  Ensure that all non-confirming activities areidentified

-  Ensure that all corrective & preventive actionsdecided are implemented

-  Request for all resources to Plot Manager-  Reporting of any abnormal situations if

occurred-  Environment control during steel cutting, crane

operations, waste handling, wastage storagespace,

-  Achievement of environment objectives andtargets

-  Review and practice of Emergencypreparedness

-  Ensure that EMS is established , implementedand maintained in accordance with ISO 14001.

-  Report the performance of EMS to director and

Plot manager for review & details ofimprovement carried out in EMS

-  Enjoys fullfreedom to takedecisions onimplementingmethodologies

of ship breaking, materialhandling on shipand on plot.

Plot ManagerDirectorGas cutterHelpers

Responsibilities, authorities and other activities of rest of employees are defined in GoodEnvironment Practices- Document Level III

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EM-00  RESPONSIBILITY MATRIX

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Clause

no.

DescriptionDirect

or

Plot

Manager

Environmentand Safety

Supervisor

1 Scope ! 

2 Normative references !  ! 

3 Definitions !  !  ! 

4 Environmental management systemrequirements !  !  ! 

4.1 General requirements !  !  ! 

4.2 Environmental policy !  !  ! 

4.3 Planning ! 

4.3.1 Environmental aspects !  ! 

4.3.2 Legal and other requirements !  ! 

4.3.3 Objectives and targets ! 

! 4.3.4 Environmental management programme(s) !  !  ! 

4.4 Implementation and operation !  ! 

4.4.1 Structure and responsibility ! 

4.4.2 Training, awareness and competence ! 

4.4.3 Communication !  ! 

4.4.4 Environmental management systemdocumentation !  ! 

4.4.5 Document control !  ! 

4.4.6 Operational control !  ! 

4.4.7 Emergency preparedness and response !  ! 

4.5 Checking and corrective action !  ! 

4.5.1 Measurement and monitoring !  ! 4.5.2 Non-conformance and corrective and preventive

action !  ! 

4.5.3 Records !  ! 

4.5.4 Environmental management system audit !  !  ! 

4.6 Management review !  ! 

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EM-00  Compatibility with other managementsystems

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This environment manual principally adheres to ISO 14001 : 1996 environmentmanagement system and incorporates provisions from other relevant andspecific national and international standards like ISO 18001 : 1999  as theorganization is already planning to implement occupational health and safetymanagement system in tandem with environment management system. Hencethere may be many instances where activities and documentation required forboth the management systems are overlapping each other which is consideredby management.

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SCOPE OF OUR MANUALEM-00 

Clause no.1 – IS0 14001 :1996

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SECTION -1

1.0 SCOPE OF OUR MANUAL

This manual specifies requirements for an environmental management system,to enable our organization to formulate policies and objectives taking intoaccount legislative requirements and information about significant environmentalimpacts. It applies to those environmental aspects, which our organization cancontrol and over which we can expect to have an influence.

This manual is applicable to our organization as we intend to:

a) Implement , maintain and improve our environmental management system;

b) Assure ourselves to the conformance of stated environmental policy;

c) Demonstrate such conformance to our employees, suppliers, regulatoryauthorities & society as a whole.

d) Seek certification of our environmental management system by suitablecertifying organization;

e) Make a self-determination and self-declaration of conformance with thisInternational Standard.

 All the requirements in this International Standard are intended to beincorporated into our environmental management system. The extent of theapplication depends on factors as the environmental policy of our organisation,the nature of our activities and the conditions in which we operate.

The scope of our activities considered for this environment management systemis “ Breaking of ships, sale of steel and other materials, components, machinery

derived from ships.” 

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NORMATIVE REFERENCESEM-00 

Clause no.2 – IS0 14001 :1996

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SECTION – 2

2.0 NORMATIVE REFERENCES

This Environment Manual principally adheres to ISO 14001 :1996Environment Management System.

Wherever appropriate, and to avoid unnecessary volume of documentreferences to existing recognized standards or documents, as describedbelow, are available to the environment manual user and are incorporated.

Srno. Standard Nomenclature

1 ISO 14001 : 1996 Environmental Management System,Specification Guidance for use

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TERMS AND DEFINITIONSEM-00 

Clause no.3 – IS0 14001 :1996

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SECTION – 3

3.0 TERMS AND DEFINITIONS

3.1 Abbreviations

Sr.No. Abbreviation Meaning

1 GEP Good Environment Practice

2 MR Management Representative

3 EMS Environment Management System

4 GMB Gujarat Maritime Board

5 ESS Environment and Safety Supervisor

6 SC Steel cutter

7 Pipe valve

(Ghadi) valve that is fitted to the pipe

connecting gas gun and cylinder8 Cylinder LPG and Oxygen cylinder

9 GPCB Gujarat Pollution Control Board

10 EMP Environment Management Program

11 I & O Implementation and Operation

12 C & CA Checking and corrective action

13 CAPA Corrective and preventive action

14 WH Waste Handler

3.2 Definitions

3.2.1 EnvironmentSurroundings in which our organization operates, including air, water, land, beach area,workers and their interrelation.

3.2.2 Environmental AspectElement of our organization’s activities which include ship breaking activity, sale of steeland other by-products derived from ship that interact with the environment.

3.2.3 Environmental Impact Any change to the environment, whether adverse or beneficial, wholly or partiallyresulting from an organisation’s activities as described above.(see 3.3)

3.2.4 Environmental Management System

The part of the overall management system that includes organizational structure,planning activities related to ship breaking , responsibilities, practices, procedures,processes and resources for developing, implementing, achieving, reviewing andmaintaining the environmental policy.

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

TERMS AND DEFINITIONSEM-00 

Clause no.3 – IS0 14001 :1996

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3.2.5 Environmental Management System Audit A systematic and documented verification process of objectively obtaining and

evaluating evidence to determine whether our organization’s environmentalmanagement system conforms to the environmental management system audit criteriaset by us, and for communication of the results of this process to top management.

3.2.6 Environmental ObjectiveOverall environmental goal, arising from the environmental policy, that our organizationhas set to achieve, and which is quantified where practicable.

3.2.7 Environmental PerformanceMeasurable results of the environmental management system, related to ourorganization’s environmental aspects, based on our environmental policy, objectives andtargets.

3.2.8 Environmental PolicyStatement by our organization of our intentions and principles in relation to our overallenvironmental performance which provides a framework for action and for the setting ofour environmental objectives and targets.

3.2.9 Environmental TargetDetailed performance requirement, quantified where practicable, applicable to theorganization or parts thereof, that arises from the environmental objectives and thatneeds to be set and met in order to achieve those objectives.

3.2.10 Interested Party

Individual or group concerned with or affected by the environmental performance of ourorganization.

3.2.11 OrganizationRUSHIL INDUSTRIES LTD. Is a closely held limited company.

3.2.12 Prevention of PollutionUse of processes, practices, materials or products that avoid, reduce or controlpollution, which may include recycling, treatment, process changes, controlmechanisms, efficient use of resources and material substitution.

3.2.13 Director

The director is one of the member of board of the organization.

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

GENERAL REQUIREMENTSEM-00 

Clause no.4.1 – IS0 14001 :1996

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4.1 General Requirements4.1.1 POLICY:

The organization (top management) has established, documented, implemented& maintained an Environment Management System and continually improve itseffectiveness in accordance with the requirements of ISO 14001 : 1996as ameans of ensuring that our activities confirm to specified requirements.

4.1.2 SCOPE :

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship.

4.1.3 RESPONSIBILITY

The Management Representative [MR] is totally responsible for implementationof this policy and achieving the purpose.

4.1.4 PROCEDURE

To implement the Environment Management System top management havecollectively worked and prepared the complete Environment manual & haveprepared and documented procedures and good environment practices whilekeeping focus on our Environment policy.

The requirements of our environment management system are described in thefollowing manual which include :

1. Environmental policy2. Planning

a. Environmental aspectsb. Legal and other requirementsc. Objectives and targetsd. Environment management programs

3. Implementation and Operationa. Structure and Responsibility

b. Training, awareness and competencec. Communicationd. Environment management system documentatione. Document controlf. Operational control

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GENERAL REQUIREMENTSEM-00 

Clause no.4.1 – IS0 14001 :1996

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g. Emergency preparedness and response4. Checking and corrective action

a. Monitoring and measurementb. Nonconformance and corrective and preventive actionc. Recordsd. Environment management system audit

5. Management Review

4.1.5 Records NIL

4.1.6 Reference Documents NIL

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

Environmental PolicyEM-00 

Clause no.4.2 – IS0 14001 :1996

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4.2 Environmental policy

4.2.1 POLICY

The top management with executive responsibility has defined and documentedenvironmental policy for our organization and its commitment to environmentcontrol.

4.2.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship.

4.2.3 RESPONSIBILITY

The environmental policy is well communicated to and understood by allemployees and accepted as a prime responsibility to comply with hence beartheir whole hearted support.

4.2.4 PROCEDURE

In establishing our organization’s environmental policy , top management hasensured that

a) Is appropriate to the nature, scale and environmental impacts of our ship

breaking activities.;

b) Includes a commitment to continual improvement and prevention of pollution;

c) Includes a commitment to comply with relevant environmental legislation andregulations as described in list of applicable legislations and regulations.

d) Provides the framework for setting and reviewing environmental objectivesand targets;

e) Is documented, implemented and maintained and communicated to all

employees;

f) Is made available to the public.

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

Environmental PolicyEM-00 

Clause no.4.2 – IS0 14001 :1996

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 After reviewing the above considerations, environmental and occupational health& safety policy of our organization is as follows:

We at RUSHIL INDUSTRIES LTD. which is a ship breaking unit are committed to continual

improvement of our occupational health & safety and environment control processes aimed at

prevention of all types of pollution and minimization of occupational health and safety risks. We

shall strive to achieve this by :

1.  Complying with applicable occupational health, safety and environment legislations

2.  Striving to achieve the occupational health, safety and environment objectives and targets

3.  Communicating this policy to all employees and make it available to interested parties and

public.

This policy shall be reviewed regularly.

=============x================x==============x===============

pyRavr` AOr Vyvsaiyk sur9a poilsI

ruxIl {NDiS3/s ilim3eD (RUSHIL INDUSTRIES LTD.) me. kam krne vale swI log pyaRvr` AOr

Vyvsaiyk sur9a ke inr.tr su2ar ke il0 yh p/` krte hE., ik

−  hm sb imlkr pyaRvr` AOr kmRcairyo. kI Vyvsaiyk sur9a ka pUra @yan rqe.ge|

−  hm pr lagU pyaRvr` AOr Vyvsaiyk sur9a ke sare kanUno. ka pUra paln kre.ge|

−   pyaRvr` AOr Vyvsaiyk sur9a ke iniXct ]deXy AOr @yey ko haisl krne kI pUrI koixx kre..ge|

−  Apne kmRcarI , ga/hk AOr sPlayr ko ApnI pyaRvr` AOr Vyvsaihk sur9a inityo.. kI jankarI

dete rhe.ge|

yh poilsI kI jankarI hmare swI 63ko. ko smy smy pr 3/ein.g AOr AapsI smvad se dete rhege |

Reference documents

EM-00 Environmental Manual

Records

NIL

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

Planning – Environmental aspectsEM-00 

Clause no.4.3.1 – IS0 14001 :1996

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4.3 PLANNING

4.3.1 Environmental aspects

4.3.1.1 POLICY :The top management of the organization has identified, established andmaintained environmental aspects of our ship breaking activity and sales of byproducts derived from the same.

4.3.1.2 SCOPE :

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.3.1.3 RESPONSIBILITYThe Director is responsible for implementation of this policy and achieving thepurpose.

4.3.1.4 PROCEDUREThe Director of the organization has identified, established and maintainedenvironmental aspects of ship breaking activity that we can control and overwhich we can be expected to have an influence as described in List of aspects[LS-MGT-01] , in order to determine those which have or can have significantimpacts on the environment as described in List of significant environment alaspects and impacts [LS-MGT-02] .

In the above process we have ensured that the aspects related to thesesignificant impacts are considered in setting our environmental objectives asdescribed in [FM-MGT-01] which is updated every 6 months.Entire details of the this activity is given in EP- 02 Procedure for identification ofenvironmental aspects.

Reference DocumentsLS-MGT-01 List of aspectsLS-MGT-02 List of significant environmental aspects and impactsFM-MGT-01 Environmental objectives and targets

EP-02 Procedure for identification of environmental aspects.

RecordsNIL

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

Planning – Legal and otherrequirementsEM-00 

Clause no.4.3.2 – IS0 14001 :1996

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4.3.2 Legal and other requirements

4.3.2.1 POLICY :

The Top management has identified and has access to legal and otherrequirements to which our organization subscribes.

4.3.2.2 SCOPE :

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.3.2.3 RESPONSIBILITY

The Director is responsible for implementation of this policy and achieving thepurpose.

4.3.2.4 PROCEDURE

The Director of the organization has identified, established and maintained legaland other requirements to which the organization subscribes, that are applicableto the environmental aspects [LS-MGT-01] of our ship breaking activity. Theapplicable legal requirements are described in List of applicable legal legislations

as described in [LS-MGT-03] Entire details of the this activity is given in EP- 01Procedure for identification of legal and other requirements.

Reference DocumentsLS-MGT-01 List of environmental aspectsLS-MGT-03 List of applicable legal legislationsEP-01 Procedure for identification of legal and other

requirements.RecordsNIL

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

Planning – Objectives and targetsEM-00 

Clause no.4.3.3 – IS0 14001 :1996

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4.3.3 OBJECTIVES AND TARGETS

4.3.3.1 POLICY

The organization has established, maintained and documented environmentalobjectives and targets, at each relevant function and level within the organization

4.3.3.2 SCOPE :

This policy is applicable to significant environmental aspects and impacts[LS-MGT-02] , its technological options and its financial, operational and businessrequirements and the views of interested parties..4.3.3.3 RESPONSIBILITY

 All Environmental objectives and targets are well communicated to andunderstood by all employees and accepted as a prime responsibility to achievethe same to comply with EMS.

4.3.3.4 PROCEDURE

When establishing and reviewing our objectives and targets as described in [FM-MGT-01], we have considered the legal and other requirements, its significantenvironmental aspects, its technological options and its financial, operational andbusiness requirements, and the views of interested parties.

The objectives and targets have been consistent with the environmental policy,including the commitment to prevention of pollution.

Reference documentsLS-MGT-02 List of significant environmental aspects and impactsFM-MGT-01 Environmental objectives and targets

RecordsNIL

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Planning – E M PEM-00 

Clause no.4.3.4 – IS0 14001 :1996

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4.3.4 Environmental management programme

4.3.4.1 POLICY :

The top management has established and maintained environmentalmanagement programme for achieving our environmental objectives andtargets [FM-MGT-01]

4.3.4.2 SCOPE :

This policy is applicable to significant environmental aspects and impacts[LS-MGT-02] , its technological options and its financial, operational and businessrequirements and the views of interested parties.

4.3.4.3 RESPONSIBILITY

The Environmental management programme is well communicated to andunderstood by all employees and accepted as a prime responsibility to achievethe same to comply with EMS.

4.3.4.4 PROCEDURE

The environmental management programme include

a) Designation of responsibility for achieving objectives and targets at eachfunction and level of the organisation;

b) The means and time-frame by which they are to be achieved.

Details of above activities can be found in Environment Management Programme[FM-MGT-02]

Reference documentsFM-MGT-02 Environment Management ProgrammeLS-MGT-02 List of significant environmental aspects and impacts

FM-MGT-01 Environmental objectives and targets

RecordsNIL

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

I & O –Structure and responsibilityEM-00 

Clause no.4.4.1 – IS0 14001 :1996

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4.4 Implementation and Operation (I &O )

4.4.1 I & O - Structure and Responsibility

4.4.1.1 POLICY :

The Top management has defined, documented and communicated roles,responsibility and authorities in order to facilitate effective environmentalmanagement.

4.4.1.2 SCOPE :

This policy is applicable to all the employees of the organization.

4.4.1.3 RESPONSIBILITY

This policy is applicable to all the employees of the organization.

4.4.1.4 PROCEDURE

Management has provided resources essential to the implementation and controlof the environmental management system. Resources include human resourcesand specialized skills, technology and financial resources.

The organisation’s top management has appointed (a) specific management

representative(s) who, irrespective of other responsibilities, have been definedroles, responsibilities and authority for

a) Ensuring that environmental management system requirements areestablished, implemented and maintained in accordance with thisInternational Standard;

b) Reporting on the performance of the environmental management system totop management for review and as a basis for improvement of theenvironmental management system.

Reference documents

EM-00 Pg 15 -18 Environmental Manual

RecordsNIL

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

I & O –Training awareness andcompetenceEM-00 

Clause no.4.4.2 – IS0 14001 :1996

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4.4.2 I & O -Training, awareness and competence

4.4.2.1 POLICY

The top management has a system to identify training needs. All personnelwhose work may create a significant impact upon the environment, are providedwith appropriate training.

4.4.2.2 SCOPE

The policy is applicable to all employees working in the organization.

4.4.2.3 RESPONSIBILITY

Plot Manager is responsible to implement this policy in the organization andachieve the purpose

4.4.2.4 PROCEDURE

The Plot Manager has ensured that all employees or members at each relevantfunction and level are aware of

a) The importance of conformance with the environmental policy and proceduresand with the requirements of the environmental management system;

b) The significant environmental impacts, actual or potential, of their workactivities and the environmental benefits of improved personal performance;

c) Their roles and responsibilities in achieving conformance with theenvironmental policy and procedures and with the requirements of theenvironmental management system, including emergency preparedness andresponse requirements;

d) The potential consequences of departure from specified operatingprocedures.

Personnel performing the tasks, which can cause significant environmentalimpacts, have been competent on the basis of appropriate education, trainingand/or experience as described in organization skill chart [FM-MGT-03] . All thetraining needs identified and provided are recorded in Identification cum training

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I & O –Training awareness andcompetenceEM-00 

Clause no.4.4.2 – IS0 14001 :1996

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form [ER-MGT-02] Entire details of the this activity is given in EP- 04 Procedurefor training awareness and competence.

Reference documentsFM-MGT-03 Organization skill chartEP-04 Procedure for training awareness and competence

RecordsER-MGT-02 Identification cum training need form

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

I & O –CommunicationEM-00 

Clause no.4.4.3 – IS0 14001 :1996

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4.4.3 I &O - Communication

4.4.3.1 POLICY

The top management had implemented system for internal and externalcommunication with regard to our environmental aspects and environmentalmanagement system.

4.4.3.2 SCOPE

The policy is applicable to all environmental aspects as described in List ofenvironmental aspects in [LS-MGT-01]

4.4.3.3 RESPONSIBILITY

Director and Plot Manager are responsible to implement this policy in theorganization and achieve the purpose

4.4.3.4 PROCEDURE

The top management has ensured that

•  Internal communication between the various levels and functions of ourorganization is carried out with regards to environment al aspects of theorganization.

•  The organization is receiving, documenting and responding to relevantcommunication from external interested parties

We have considered processes for external communication on our significantenvironmental aspects[LS-MGT-02] and record its decision as described in [ER-MGT-01] Entire details of the this activity is given in EP- 05 Procedure for internaland external communication.

Reference documentsLS-MGT-02 List of significant environmental aspects and impactsEP-05 Procedure for internal and external communication

RecordsER-MGT-01 External communication register

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

I & O – EMS Documentation &Document Control

EM-00 Clause no.4.4.4 & 4.4.5

IS0 14001 :1996

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4.4.4 I & O - EMS Documentation

4.4.4.1 POLICY

The top management has established and maintained information in paper formrelated to entire EMS.

4.4.4.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.4.4.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible toimplement this policy in the organization and achieve the purpose

4.4.4.4 PROCEDURE

The system for control of documents is designed in such a way that ;

a) They are located;

b) They are periodically reviewed, revised as necessary and approved foradequacy by authorised personnel;

c) The current versions of relevant documents are available at all locationswhere operations essential to the effective functioning of the environmentalmanagement system are performed;

d) Obsolete documents are promptly removed from all points of issue and pointsof use, or otherwise assured against unintended use;

e) Any obsolete documents retained for legal and/or knowledge preservation

purpose are suitably identified.

Our documentation is legible, dated (with dates of revision) and readilyidentifiable, maintained in an orderly manner and retained for at least 3 years.

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I & O – EMS Documentation &Document Control

EM-00 Clause no.4.4.4 & 4.4.5

IS0 14001 :1996

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The complete hierarchy of documentation maintained for ISO 14001:1996 EMS

can be found in Master list of documents [ML-MGT-01]

The documentation is divided in four levels i.e.

Level I Environmental Manual

Level II Environmental Procedures

Level III Good environmental practices

Level IV Environment records

Entire details of the this activity is given in EP- 03 Procedure for document anddata control.

Reference documentsML-MGT-01 Master list of documentsEP-03 Procedure for document and data control

RecordsER-MGT-03 Details of obsolete documents

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

I & O – Operational ControlEM-00 

Clause no.4.4.6 – IS0 14001 :1996

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4.4.6 OPERATIONAL CONTROL

4.4.6.1 POLICY

The top management has identified the operations and activities that areassociated with significant environmental aspects[LS-MGT-02] in line with ourpolicy, objectives and targets.

4.4.6.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.4.6.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible toimplement this policy in the organization and achieve the purpose

4.4.6.4 PROCEDURE

We have planned the activities, including maintenance, in order to ensure thatthey are carried out under specified conditions by

a) Establishing and maintaining documented procedures to cover situationswhere their absence could lead to deviations form the environmental policy

and the objectives and targets;

b) Stipulating operating criteria in the procedures;

c) Establishing and maintaining procedures related to the identifiable significantenvironmental aspects of goods and services used by the organisation andcommunicating relevant procedures and requirements to suppliers andcontractors.

Entire details of this activity are given in EP- 07 Procedure for Monitoring,measurement & control of operations. Weekly operations records are maintainedin Operations control sheet [ER-MGT-04], Maintenance control sheet [ER-MGT-

05].Reference documentsLS-MGT-02 List of significant environmental aspects and impactsEP-07 Procedure for monitoring, measurement and control

of operations

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I & O – Operational ControlEM-00 

Clause no.4.4.6 – IS0 14001 :1996

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RecordsER-MGT-04 Operations control sheetER-MGT-05 Maintenance control sheet

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

I & O – Emergency preparedness andresponseEM-00 

Clause no.4.4.7 – IS0 14001 :1996

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4.4.7 EMERGENCY PREPAREDNESS AND RESPONSE

4.4.7.1 POLICY

The top management has established and maintained procedures to identifypotential for and respond to accidents and emergency situations, and forpreventing and mitigating the environmental impacts that may be associated withthem.

4.4.7.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products

and by-products derived from the ship

4.4.7.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible toimplement this policy in the organization and achieve the purpose

4.4.7.4 PROCEDURE

We have reviewed and revised, where necessary, its emergency preparednessand response procedures, in particular, after the occurrence of emergency drills.

We have also periodically tested such procedures which can be verified inEmergency drill record [ER-MGT-08]

Entire details of the this activity is given in EP- 08 Procedure for Identification andcontrol of emergency situations.

Reference documentsEP-08 Procedure for identification and control of emergency

situations.

RecordsER-MGT-08 Emergency drill record

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

C & CA – Monitoring and measurementEM-00 

Clause no.4.5.1 – IS0 14001 :1996

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4.5 Checking and Corrective action4.5.1 Monitoring and measurement

4.5.1.1 POLICY

The top management has established and maintained various procedures tomonitor and measure, on a regular basis, the key characteristics of its operationsand activities that can have a significant impact on the environment.

4.5.1.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.5.1.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible toimplement this policy in the organization and achieve the purpose

4.5.1.4 PROCEDURE

The above activity include the recording of information to track performance,relevant operational controls and conformance with the organisation’senvironmental objectives and targets which can be verified in Operations controlsheet [ER-MGT-04] and Maintenance control sheet [ER-MGT-05]

Monitoring equipment is calibrated and maintained and records of this processare retained according to the organisation’s procedures which can be found inMaintenance and calibration plan [ER-MGT-06] and Calibration control sheet[ER-MGT-07].

The Director evaluates compliance with relevant environmental legislation andregulations every 6 months or during any receipt of new legislation or externalcommunication.

Entire details of the this activity is given in EP- 07 Procedure for Monitoring,

measurement & control of operations.

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

C & CA – Monitoring and measurementEM-00 

Clause no.4.5.1 – IS0 14001 :1996

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Plot Manager

Released by

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Authorized By

Director

Page 42 of 46

Reference documentsEP-07 Procedure for monitoring, measurement and control

of operations.ER-MGT-06 Maintenance and calibration control plan

RecordsER-MGT-04 Operations control sheetER-MGT-05 Maintenance control sheetER-MGT-07 Calibration control sheet

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

C & CA – Non conformance and CAPAEM-00 

Clause no.4.5.2 – IS0 14001 :1996

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4.5.2 Non - Conformance and CAPA4.5.2.1 POLICY

The top management has defined responsibility and authority for handling andinvestigating non-conformances, taking action to mitigate any impacts causedand for initiating and completing corrective and preventive action.

4.5.2.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.5.2.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible toimplement this policy in the organization and achieve the purpose

4.5.2.4 PROCEDURE

 Any corrective or preventive actions taken to eliminate the causes of actual andpotential non-conformances are ensured that they are appropriate to themagnitude of problems and commensurate with the environmental impactencountered.

The top management has implemented and recorded any changes in the

documented procedures resulting from corrective and preventive action whichcan be reviewed in ER-MGT-14 Change in procedures.

The entire details of the above activity is described in details in EP-09 Control ofnon-conformances, corrective and preventive action

Reference documentsEP-09 Procedure for Control of non-conformances,

corrective and preventive action

Records

ER-MGT-14 Change in procedures

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Rev no.00 Dt 05.11.04

Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

C & CA – Control of recordsEM-00 

Clause no.4.5.3 – IS0 14001 :1996

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4.5.3 CONTROL OF RECORDS4.5.3.1 POLICY

The top management has planned, established and maintained the identification,maintenance and disposition of environmental records.

4.5.3.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.5.3.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible toimplement this policy in the organization and achieve the purpose

4.5.3.4 PROCEDURE

The top management has ensured that environmental records are legible,identifiable and traceable to the activity, product or service involved.Environmental records are stored and maintained in such a way that they arereadily retrievable and protected against damage, deterioration or loss. Theirretention times has been established and recorded. Records are maintained, asappropriate to the system and to the organisation, to demonstrate conformanceto the requirements of this International Standard. The entire details of the above

activity is described in details in EP-06 Control of records. A list of all the recordsto be maintained can be found in Master list of documents [ML-MGT-01]

Reference documentsEP-06 Procedure for Control of records

RecordsML-MGT-01 Master list of documents

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Issue no.A Dt 05.11.04 RUSHIL INDUSTRIES LTD.

C & CA – EMS AuditEM-00 

Clause no.4.5.4 – IS0 14001 :1996

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4.5.4 Environmental Management System (EMS) Audit

4.5.4.1 POLICY

The top management has planned for periodic environmental managementsystem audits to be carried out every 6 months.

4.5.4.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.5.4.3 RESPONSIBILITY

Director, Plot Manager and Environment and Safety Supervisor are responsibleto implement this policy in the organization and achieve the purpose

4.5.4.4 PROCEDURE

Environmental audits are conducted in order to

a) determine whether or not the environmental management system1) conforms to planned arrangements for environmental management

including the requirements of this International Standard; and2) has been properly implemented and maintained; and

b) provide information on the results of audits to management.

The organization’s audit plan[ER-MGT-11] including any schedule, is based onthe environmental importance of the activity concerned and the results ofprevious audits. In order to be comprehensive, the audit procedures[EP-03] havecovered the audit scope, frequency and methodologies, as well as theresponsibilities and requirements for conducting audits and reporting results. Theresults of internal audit can be found in Internal audit report [ER-MGT-12]

Reference documents

EP-03 Procedure for Control of Internal environment audits

RecordsER-MGT-12 Internal audit report

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Management ReviewEM-00 

Clause no.4.6 – IS0 14001 :1996

P d b R l d b A th i d B

4.6 MANAGEMENT REVIEW

4.6.1 POLICY

The organisation’s top management every 6 months, reviews the environmentalmanagement system, to ensure its conducting suitability, adequacy andeffectiveness.

4.6.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of productsand by-products derived from the ship

4.6.3 RESPONSIBILITY

Director and Plot Manager are responsible to implement this policy in theorganization and achieve the purpose

4.6.4 PROCEDURE

The management review process ensures the necessary information is collectedto allow management to carry out this evaluation. This review is documented inRecords of management review [ER-MGT-13]

The management review addresses the possible need for changes to policy,objectives and other elements of the environmental management system, in thelight of environmental management system audit results, changingcircumstances and the commitment to continual improvement.

Reference documentsNIL

RecordsER-MGT-13 Records of Management Review


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