Environmental, Health and Safety Program Template
Environmental, Health and Safety Program
Table of Contents
I.OBJECTIVE AND SCOPE
II.RESPONSIBILITIES
A.Operations Group Management
B.Facility Manager
C.Facility EHS Coordinator
D.Supervisors
E.Employees
F.Corporate Safety Director and Corporate Environmental Manager
III.PROCEDURE
A.Applicability
B.Implementation
C.Administration
D.Basic EHS Rules
E.Enforcement of EHS Program Requirements
IV.TRAINING
A.Training
B.Training Records
V.REFERENCES
A.Regulatory references
B.NCH Policy references
C.Business Unit Policy references
D.Site Policy references
VI.APPENDICES
- Facility Policy Statement
VII.DOCUMENT CONTROL
Environmental, Health and Safety Program
for
[Company Name/Location]
- OBJECTIVE AND SCOPE
[Company Name/Location] management believes that damage to the environment and injuries, illnesses, incidents and accidents are preventable. Events such as these may result in loss or waste of company resources and are especially objectionable when any person suffers an injury or illness. [Company Name /Location] requiresthatinjury, illness, incident andaccident prevention and preservation of the environment be prime concerns of all employees.
Our goal is to ensure the safety and well being of our employees, subcontractors and customers; ensure the protection of our environment; and prevent wasteful, inefficient operations and potential damage to property and equipment. The [Company Name/Location] Environmental, Health and Safety (EHS) Program is designed to achieve and maintain these goals. A copy of the facility EHS Program is available to all employees, contract labor and third party contractors.
The [Company Name/Location] EHS Program consists of the NCH Corporation Global EHS Policy, the facility’s EHS Policy and the various plans, programs and procedures put in place by the facility to comply with governmental regulations and to meet corporate expected EHS standards (hereinafter referred to as the “EHS Program”). This program sets forth basic, fundamental and overarching principles that apply to all facility EHS plans, programs and procedures so that they are coordinated and interdependent with each other.
Compliance with the facility’s EHS Program is mandatory for all employees of the company as well as for contract labor and third party contractors working on [Company Name/Location] premises.All individuals covered by the EHS program are responsible for continuous compliance with the program.
The procedures described in the EHS Program are intended to protect employees, provide for and maintain a safe workplace, preserve and protect the environment, and facilitate compliance with applicable governmental regulations. If there is a conflict between any part of the EHS Program and a governmental regulation, the governmental regulation will apply and the EHS Program will be modified. However, all other requirements in the EHS Program shall apply even if more stringent than governmental regulations, unless there is a specific written determination that a particular requirement within a Program is not applicable to the facility. Such determination shall state with particularity why that portion of the Program is inapplicable.
II.RESPONSIBILITIES
- Operations Group Management
Operations Group Management consists of the business unit management team, including those managers to which facility managers are accountable. Operations Group Management will demonstrate concern for the safe conduct of all business operations by:
1.Establishing a reporting system that will provide adequate data on the success of the EHS Program in all company operations within its area of responsibility.
2.Periodically, but no less than annually, participating in review of the EHS Program and its effectiveness.
3.Using environmental and safety performance metrics in developing performance evaluations.
4.Ensuring that resources are available to support compliance with the facility’s EHS Program.
- Facility Manager
[Facilities Manager], as the Facility Manager, is responsible for maintaining an effective effort to comply with the NCH and facility EHS Programs within his or her area of responsibility. The Facility Manager has ultimate responsibility for the EHS Program at this location. Authorization and responsibility for deployment of the EHS Program is vested in the Facility Manager, the various individuals identified in each individual plan or program and, if in place, the [Company Name/Location] EHS Committee.
The safety and health of all personnel and compliance with all environmental requirements within a given facility are the responsibility of the facility manager. The Facility Manager will administer an effective EHS program and provide leadership required for it to be an integral part of daily operations. To do this, the manager shall:
1.Become familiar with and meet all aspects and requirements of the NCH and facility EHS Program.
2.Attend EHS meetings to support the program.
3.Review all accident and incident reports to be fully aware of necessary corrective and preventive actions and identify any trends which may have developed.
4.Personally review serious accidents and incidents to determine if all aspects of the accident or incident have been investigated and addressed.
5.Integrate EHS performance and requirements into periodic meetings with all levels of management.
6.Make informal inspections on a regular basis.
7.Share experience, knowledge, corrective actions and suggestions for improvement with colleagues to enhance facility programs.
8.Provide adequate controls to ensure that EHS requirements are strictly enforced.
9.Enforce strict housekeeping measures to facilitate a safe work environment.
10.Understand the Emergency Action Plan and ensure that the emergency response personnel in the facility are staffed, trained and equipped to respond safely and effectively.
11.Include EHS performance as an important criterion in each employee's performance evaluation.
12.Designate individuals within the facility to fulfill the responsibilities of each of the individual plans and programs. Name one or more person(s) to be the EHS coordinator(s).
13.Communicate to the facility employees the requirements of the various programs applicable to their work areas and convey to employees by example and in clear, unequivocal language the importance of environmental, health and safety in any job to be performed.
- Facility EHS Coordinator
The responsibility for overseeing implementation of the EHS program may be vested in one individual at [Company Name/Location]. [Responsible Person] shall be the facility EHS Coordinator. The EHS Coordinator will:
- Develop and implement a thorough and meaningful written facility-specific EHS Program.
- Schedule and conduct EHS committee meetings which [Company Name/Location] has voluntarily established.
- Schedule and conduct or participate in periodic facility or departmental EHS meetings for employees.
- Lead investigation of serious accidents.
- Ensure the appropriate selection, procurement and adequate supply of proper personal protective equipment and emergency response supplies, in proper repair.
- Conduct periodic EHS inspections of the facility, document the findings and report results in writing to the facility manager.
- Ensure that any EHS reporting and recordkeeping requirements are met.
- Create and maintain files, in accordance with the facility’s Document Retention Plan, on EHS records such as:
- Employee training records.
- Incident Investigation Reports.
- Accident Investigation Reports.
- Employer's First Report of Injury.
- New Employee (Orientation) Checklists.
- Facility EHS Inspection Reports.
- Minutes of EHS meetings.
- Permits for Hot Work and Confined Space Entry.
- All governmental reports and supporting documentation.
- All data such as emissions, discharge, waste and safety data when required.
- All information needed to measure performance.
- Schedule and oversee or direct emergency response personnel training.
- Conduct assessments of employees’ exposure to chemicals or other harmful agents involved in any operation. This duty may be delegated. Copies of all assessment reports must be submitted to the Corporate Safety Director for review.
D.Supervisors
An essential element of the EHS Program is the front-line supervisor because of the managerial relationship and frequent contact with employees. As such, all supervisors must make a concerted effort to sustain the EHS Program on a daily basis. Each supervisor shall:
- Be an example of EHS in practice, both on and off the job. Comply with all facility EHS procedures.
- Enforce the facility EHS procedures at all times.
- Continuously inspect the work area for EHS concerns and ensure deficiencies are corrected. When EHS concerns are found outside his/her area, report them promptly to the appropriate supervisor or manager.
- Promptly correct all identified EHS concerns or advise the manager why necessary corrections cannot be made, and what interim measures are being taken to address the concerns.
- Ensure that all incidents and accidents are investigated and that all employees are aware of the cause of the event or condition and what measures are being taken to prevent similar mishaps. Report all such injuries, illnesses, incidents and accidents to [Responsible Person(s)] on the same day of the occurrence or as soon as reported.
- Ensure that all employees are trained in the safe methods of performing their job responsibilities.
- Work to develop proper EHS attitudes in each employee: "No job is so important that we cannot take time to perform our work in a safe and environmentally protective manner."
E.Employees
All employees share an important role in deployment of an effective EHS program. All employees are responsible and will be held accountable for complying with the EHS Program. Failure to comply with the EHS Program is a violation of the Program and may result in progressive disciplinary action up to and including termination in accordance with company policies. All employees are responsible for:
- Following all written and oral instructions.
- Avoiding unnecessary exposures to hazards.
- Knowing the location of all emergency protective equipment in the work area.
- Knowing and following the emergency procedures prepared for the facility.
- Reporting immediately all work related injuries, illnesses, incidents and accidents.
- Reporting all unsafe or unacceptable environmental conditions or actions to the supervisor.
- Actively participating in EHS activities such as EHS committees, investigation teams and peer advisory roles when requested.
- Develop and work with the proper EHS attitudes that: "No job is so important that we cannot take time to perform our work in a safe and environmentally protective manner."
F.Corporate Safety Director and Environmental Manager
A Corporate Safety Director and a Corporate Environmental Manager will coordinate NCH’s corporate EHS programs and serve as resources to management in their efforts to establish and maintain a safe and healthy working environment and to preserve and protect the environment.
III.PROCEDURE
A.Applicability
This EHS Program applies to all employees of [Company Name/Location] regardless of position within the company. This Program, as set forth in the individual programs and plans, applies to all persons, including third party subcontractors, while on company premises. Every person covered by this Program is also required to comply with all other applicable governmental requirements.
B.Implementation
1.Management commitment to Environment, Health and Safety
NCH Corporation has issued a Global EHS Policy establishing its commitment to providing a safe workplace and protecting our environment. Therefore:
a.The Group Operations Manager or Facility Manager has published a written statement which expresses [Company Name/Location]’s commitment to a safe and healthy workplace. See Appendix A.
b.The written statement may be found in Appendix A and [identify where the statement is posted, in what documents it is published and from whom it is available.]
c.[If the facility chooses to have a committee - A EHS Committee has been established for [Company Name/Location].
i.It is chaired by [Facility Manager or Facility EHS Coordinator].
ii.The EHS Committee is composed of facility managers, supervisors and non-management employees selected [describe selection process].
iii.The EHS Committee will meet at least quarterly to evaluate all areas of the EHS Program, make recommendations to strengthen [Company Name/Location] EHS programs and plan and develop EHS programs for implementation as appropriate.]
2.EHS Meetings will be scheduled to train employees in accordance with the facility’s Training Plan.
3.Job hazard analysis (JHA) for duties assigned to employees.
a.A written job hazard analysis should be conducted in accordance with the facility’s PPE Program, Fall Protection Program, Hazardous Communication Program and such other programs as may be applicable.
b.All employees assigned to a job for which a job hazard analysis is required will be trained.
4.Recognition of exemplary safety performance.
a.The Group Operations Manager or Facility Manager will publicly recognize exemplary EHS performance by individuals, work groups or entire operations. Examples of performance that warrant recognition include:
i.an employee’s satisfactory completion of a safety certification program such as an OSHA 10 hour card;
ii.receipt of a public or corporate safety award by an individual, group or team; or
iii.outstanding safety performance such as 1 quarter or 1 year with no lost time injuries or illnesses.
b.The Group Operations Manager or Facility Manager should forward copies of such recognition to the Office of Regulatory Affairs for inclusion in NCH’s EHS performance metrics compilation.
C.Administration
The EHS Program will be deployed and maintained in accordance with procedures and guidelines established and published in this and other [Company Name/Location] and NCH related programs.
D.Basic EHS Rules
1.Every employee and person covered by this program is required to:
a.Comply with applicable governmental requirements and company EHS rules is a condition of employment.
b.Report all injuries, illnesses, incidents and accidents, regardless of how minor, to the employee’s supervisor and the Facility EHS Coordinator immediately. In the event of an accident involving personal injury or damage to property, submit to drug testing.
c.Use required personal protective equipment (PPE) such as safety glasses, chemical goggles, chemical protective clothing and hard hats when in an area or while performing a task where PPE is required. PPE will be worn in compliance with the manufacturer’s instructions and as specified in special training by [Company Name/Location]. Employees are not authorized to alter or modify PPE.
d.Wear work clothing in compliance with [Company Name/Location] policies and appropriate for the work conditions. Employees may be required to wear uniforms or specific pieces of clothing for employee safety or product quality protection.
e.Attend EHS meetings as stipulated by facility managers or supervisors.
2.Firearms, alcoholic beverages or illegal drugs are not allowed on company property or in company vehicles at any time. Use or possession of illegal drugs or alcoholic beverages on the jobsite may result in disciplinary actions up to and including immediate termination in compliance with [Company Name/Location] policies.
3.If an employee is assigned operate potentially dangerous equipment such as a forklift or work in a hazardous chemical location and has been prescribed a medication by a physician, the employee should discuss potential EHS issues with [Responsible Persons].
4.Housekeeping shall be an integral part of every job. Supervisors and employees are responsible for keeping their work areas clean and hazard-free. Clean up is required when clutter, waste or spills present a potential hazard and at least at the end of each shift.
5.All hot work will be conducted in full compliance with [Company Name/Location]’s Hot Work Permit Program.
6.All tools and PPE whether company or personal, must be maintained in good working condition. Employees will not use defective or worn tools or PPE. Defective tools and PPE will be brought to the attention of the immediate Supervisor. Examples include chisels with mushroomed heads, hammers with loose or split handles, guards missing on saws or grinders, extension cords with compromised insulation, torn gloves, improper fitting respirators, etc.
7.All extension cords, drop cords, and electrical tools shall be checked before use. Tools will be properly grounded before use. Cords and equipment that do not meet requirements shall be immediately tagged and removed from service until repairs have been made.
8.“Horseplay" on the jobsite is strictly prohibited. Running on the jobsite is allowed only in extreme emergencies.
9.No employee will store, prepare or consume food in workplace locations where hazardous materials are present.
10.No employee may store or use tobacco or substitute tobacco products, store or apply cosmetics of any kind, or store or consume beverages in workplace locations where hazard materials are present unless provisions have been made by [Company Name/Location].
11.Employees and Third Party Contractors must report all unsafe conditions or environmental risks to [Responsible Persons] so corrective action can be taken.
12.Warning signs, barricades, and tags will be used as appropriate to warn employees, third party contractors and visitors of hazardous conditions.
13.All employees and third party contractors will comply with [Company Name/Location] and governmental EHS standards.
E.Enforcement of EHS Program Requirements
Violations of [Company Name/Location]’s EHS Program requirements are considered serious infractions of [Company Name/Location] Policy. Allemployees and Third Party Contractors will be held accountable in accordance with [Company Name/Location] and NCH Policies.
1.Any single violation of or a documented history of disregard for [Company Name/Location] EHS Program requirements may result in disciplinary action up to and including termination in accordance with company policies.
2.Failure to use safety systems or equipment designed to protect the environment such as interlocks, fall protection, required Personal Protective equipment, air scrubbers, secondary containment systems, etc; or failure to timely report work related injuries, illnesses, incidents or accidents may result in disciplinary action up to and including termination in accordance with company policies.
IV.TRAINING
A.Training
The Facility EHS Coordinator will determine and document the population who requires training under the different individual plans and programs in accordance with the facility’s Training Plan.