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IMS / Q100/ 00 Rev 1 – 11/14 Page 1
for
Registered Address of Company
"Stoneycroft House", 36 Oldfield Way, Heswall, Wirral, Merseyside. CH60 6RH
Written by
Ms. Brigitte Guile MA (EPS), Pg D(EDM), MCIWM, FGS, AIEMA, BSc(hons) Chartered Waste Manager & Sustainability Consultant for
www.d100comms.co.uk
IMS / Q100/ 00 Rev 1 – 11/14 Page 2
Section: Contents: Page No:
1.0 Introduction 3
2.0 Health and Safety Policy 4 2.1 Health and Safety Objectives: 2.2 Planning
2.3 Emergency Contact Numbers 2.4 Client Related Emergency Contact / Response Numbers 2.5 Communication of HS Policy 2.6 Journey Management Plans
3.0 Environment Policy 6
3.1 Aspects and Impacts 3.2 Objectives 3.3 Waste 3.4 Material Use
4.0 Quality Policy 9
4.1 Management Responsibilities 4.2 Resource Management 4.3 Resource Inspection Reports 4.4 Measurement Analysis & Improvement
5.0 Environmental Planning 11
5.1 Environmental Aspects Analysis 5.2 Legislation 5.3 Objectives and targets
6.0 IMS Implementation and Operation 13
6.1 Structure and Responsibilities 6.2 Training and Competence 6.3 Communications 6.4 Documentation 6.5 Emergency Preparedness and Response
7.0 Checking and Corrective Action 16
7.1 Monitoring and Measurement 7.2 Records and Record Management 7.3 Non-conformance, Prevention and Corrective Action 7.4 Evaluation of Compliance 7.5 Internal Audits
8.0 Management Review 18
9.0 Terms and Definitions 19
9.1 References 20 9.2 Appendices 21
IMS / Q100/ 00 Rev 1 – 11/14 Page 3
Apex Marine Consultants Limited Integrated Management System (IMS)
8.5 INTRODUCTION
This document describes the Apex Marine Consultants (AMC) Limited Integrated Management System (IMS). It translates the goals and intentions of AMC’s QHSE Policies into actions required from the management system. All contractors and affiliates assigned projects by AMC will be expected to follow these policies and implement actions accordingly.
The structure of the IMS has been developed in line with three recognized standards for health and safety BSI OHSAS 18001; ISO 14001 on Environmental Management Systems & ISO 9001 for Quality. By utilizing this system, AMC will embrace the key elements to establish a healthy, safe management system with quality attributes including important consideration for lowering the impacts upon the environment. Thus, AMC will produce superior reports for its clients from its resource inspection and analysis using the most cost-effective methods.
Figure 1: The IMS Structure
Each area of the IMS will have its own policy signed by the AMC managing director and with its own targets and objectives. Planning and Implementation will commence accordingly within European, UK legislation and local regulations. AMC will also follow best practice in all of its operations and the information for all three areas will be collated and contained in the one AMC integrated management system.
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2.0 Health and Safety Policy
2.1 Health and Safety Objectives:
AMC realizes the importance of health and safety in all areas of its business and strives to instil a healthy, safe environment throughout all of its operations worldwide. AMC will comply with all UK health and safety legislation as well as European Directives, world-wide initiatives and industry best practice. The responsibility to identify local Health and Safety legal requirements and ensure compliance is that of the attending Expeditor where relevant.
The Managing Director is responsible and accountable for the ensuring that health and safety methodologies are communicated to all of its expeditors with written evidence of training records. H & S training and competence records will be kept up to date and available on request to clients. AMC will reiterate inherent safety for contractors; the hierarchy of prevention as the first step with observational actions to follow with detection, control and mitigation. The aim being, to conduct the resource testing whilst enabling processing procedures to continue with continued process integrity in a safe and healthy environment.
2.2 Planning:
The importance of working in a safe operating envelope with risk assessments following the five step procedure will be emphasized. On occasion, a simplified risk assessment will be undertaken based on the exact low-risk nature of the business. The risk assessment will include a hazard analysis, potential harm, precautionary measures, evaluation records and review. The risks are generally well-known in resource inspection but the expeditor will need to familiarize him/herself with the MSDS for the particular resource required to evaluate to ensure that the risk meets with the . ALARP principles will be taken into account in risk assessments to ensure risk has been evaluated ‘as low as reasonably practicable’ when used with best practice methodologies. As a minimum the risk procedure must include:
• Conduct site tour identifying potential hazards including: sources of fuel for a fire; fire ignition sources such as electrical equipment; escape route blockage; unguarded equipment; gas hazards; poor house-keeping eg slips trips and falls etc.
• Review presence and condition of protective systems such as fire detection and protection equipment and associated maintenance records.
• As far as is reasonably practicable, take action to eliminate hazards to prevent incidents occurring and protect people from consequences.
For every assignment the expeditor will be aware of:
• Knowledge of the material / product / crude oil to be exposed to by being provided with a Material Safety Data Sheet (MSDS).
• Knowledge of Client’s Life Saving Rules. • AMC and Client’s company policies • Knowledge of specific legislation pertaining to ship • Launch vessel safety assessment • Requirements for production of Journey Management Plans • Requirements for safety and performance observations on Inspection Companies, including
marine operators • Requirements for emergency preparedness aboard, including: preparation of plans, drills
and exercises. • Management of project specific HS documentation, incident reporting and records
IMS / Q100/ 00 Rev 1 – 11/14 Page 5
The responsibility for ensuring preparation, maintenance and implementation of the Risk Assessment Procedure is that of the AMC Expeditor at each location. The above HSE guidelines must be developed, taking due account of applicable local HSE regulations as advised by, and in consultation with, the local terminal / ship authorities.
2.3 Emergency Contact Numbers.
AMC will ensure that information regarding accidents and the ‘Reporting of Injuries, Diseases and Dangerous Occurrences Regulations’ (RIDDOR) is conveyed to contractors so that ‘RIDDOR 1995’ is adhered to, in order to ensure records and compliance is maintained. Incidents that occur offshore are reported on:
• Major injuries and fatal accidents -Telephone: 0845 300 9923 (Monday to Friday – 08.30 to 17.00)
• Non major accidents and dangerous occurrences Internet: RIDDOR – website (24 hours) In case of emergency during assignments (on a personal level). Contact Apex Marine Office (24/7) :- +44 151 342 3341 1st Mobile (24/7) :- +44 7860 501676 2nd Mobile (24/7) :- +44 7795 816001 2.4 Client Related Emergency Contact / Response Numbers Client’s emergency contact / response details are contained in the appointment emails issued to Expeditors before embarking on their individual assignment. 2.5 Communication of HS Policy
A copy of the company’s HS Policy must be given to:
• All Expeditors during an initial induction • Employees working in the company offices or other company locations.
A copy of the company’s HS Policy must be displayed in a prominent location at each company office to allow perusal by visitors and other interested parties.
The General Manager and / or nominated Project Manager will maintain the H & S policies which will be available to all interested parties on the company website. Management will be review the policies on a regular basis and incorporate the policy actions into all of AMC’s operations.
2.6 Journey Management Plans
Journey Management Plans must be relevant to the particular circumstances covered. An example Journey Management Plan and Risk Assessment Procedure has been developed by STASCO for use as a basis for Apex Marine’s future plans and procedures. The JMP is intended for non-professional drivers, typically in passenger vehicles for trips over 4.5 hours and less than 10 hours. A more detailed JMP may be required in high-risk countries or where required by your business. Records of risk assessments, when applicable, carried out under a Journey Management Plan, must be recorded and maintained as part of the final report submitted to the client.
Signed by: Date:
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3.0 Environment Policy
3.1 Objectives:
AMC management recognizes that all of their operations have direct and indirect impacts upon the environment and to counteract the effects, will undertake actions to reduce our influence. AMC understands that there are several globally-constructed conventions and protocols that have been implemented into nations’ policies and legislation to reduce the impacts on the environment due to long-term and trans-boundary effects.
The managing director has overall responsibility for operational controls that AMC and contracted expeditors have on climate change, resource-use, waste, pollution, and water use therefore AMC will ensure that the expeditors are aware and trained in environmental awareness.
AMC will ensure that all staff and contractors are aware of this AMC policy, environmental legislation, European Directives and over-arching protocols and conventions on climate change, biodiversity, stratospheric ozone depletion, acid rain and desertification. The expeditor will consider the environmental legislation pertaining to the assigned ship and cargo in the local context.
The aim of this policy is to guide AMC and its contractors into conducting business with minimal environmental impact in line with client contractual expectations. Operations will be evaluated using a whole life cost and a life cycle analysis. By utilizing these methodologies, AMC will be choosing the most sustainable options in business cases and operations. This will result in the most cost-effective and best environmental options in company manoeuvres and procedures with the objective of reducing global environmental issues and aiding governments to meet their targets.
Environmental Management is an area that has grown extensively in recent years as science has revealed the impacts that industry and humankind have had on the environment. There are three cornerstones to consider when implementing an EMS which is combined and known as the ‘triple bottom line’:
Figure 2: The Triple Bottom Line
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3.2 Waste:
Waste has extensive direct and indirect impacts on the environment particularly if it is sent to landfill, therefore AMC will endeavour to separate waste into recycling fractions to be sent for reuse and recycling so that materials can be reclaimed as a commodity for further use.
The European Waste Framework Directive has recently been implemented into national governments but the main aim of the directive is to consider the waste hierarchy before deciding on how to dispose of a commodity:
Figure 3 : Waste Hierarchy
AMC uses electronic equipment to conduct resource-testing and periodically they fail to work according to the manufacturers’ instructions so AMC will either dispose of the components under the Waste of Electrical and Electronic Equipment (WEEE) 2006 legislation or will send the equipment for repair if it is feasible?
AMC uses paper in signed contracts and records which is often unavoidable, however, policies can be given to staff and contractors electronically and where feasible should be communicated by using this method.
Confidential paper will be shredded and sent for recycling or composted within home composters accordingly.
Used paper that has no identifiable information on it will be collected separately and recycled.
The Waste Batteries and Accumulators Regulations 2009 set out rules for collecting, treating and recycling all types of batteries in the UK. AMC will collect all batteries separately and dispose of them at the local recycling facility accordingly. Cardboard and plastic packaging will be collected separately and recycled at local recycling facilities.
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3.3 Material Use:
Although AMC is working with fuel resources, management realizes the requirement to manage its own fuel resources wisely due to escalating costs and diminishing world-wide resources. The United Nations Framework Conventions on climate change, desertification and biodiversity have been signed and ratified by most of the world countries with the overarching aim of leading the world to Sustainable development.
The term coined by Harlem Brundtland in 1987 at a UN summit in Copenhagen, determined that Sustainable Development is development that meets the needs of the current generation but equally allows future generations to meet their own requirements. AMC realizes that it is not only sensible to reduce energy-use for the world to meet its obligations to future generations but logical due to cost escalations in energy from fossil fuels.
AMC will strive to reduce impact on trees and carbon sequestration by ensuring that documents will be printed using both sides of a piece of paper. The company will retain information and submit documents electronically where possible.
A life cycle analysis and whole life costing will be undertaken when feasible, during procurement of goods and services. AMC realizes that in some fields, there is limited choice in procurement of specialist electronics and as such, the most cost-effective equipment will be chosen.
Transport has considerable direct and indirect impacts upon the environment affecting local air quality with air pollutants, Nox, CO, tropospheric ozone, particulate matter, and hydrocarbons. Road transport accounts for 22% of the climate changing greenhouse gases and in particular CO2 emissions in the UK. 10% of greenhouse gases is derived from manufacture of the vehicles in the first place whilst 5% comes from vehicle disposal. New technologies are improving dramatically in this area and helping to improve air quality however AMC realizes that travel forms a large part of their operations and so AMC will limit business travel, where possible, to reduce impact on climate change and encourage expeditors to use public transport, where possible and if feasible!
Water is a non-renewable resource in many countries due to the amount of energy required to separate sea water into fresh water therefore during AMEC operations expeditors should be vigilant in observing working behaviours of others to avoid water course pollution and avoidable unnecessary water use.
AMC management will ensure that adequate environmental awareness training is communicated to all staff and expeditors during inductions and records for these actions will be kept with other training in the IMS. Staff training will be reviewed annually and updated as legislation changes and technologies improve. Communications will be relayed via the website with newsflashes and email.
Signed By: Date:
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4.0 Quality Policy
A QMS is defined as “A set of co-ordinated activities to direct and control an organisation in order to continuously improve the effectiveness and efficiency of its performance.” AMC believes that with the aim of a quality system at the heart of our operations, the final reports that we are working towards for our clients, will be prepared with a methodical set of tried and tested actions together within a logical set of quality-based controls. The controls are implemented to reduce risk to business and improve profitability by identifying weak areas in the system and unnecessary expenses. The basic quality management system follows four linked processes:
• Management Responsibilities • Resource Management • Product Realization (Resource-inspection Reports) • Measurement, Analysis & Improvement
When staff and expeditors follow a well-constructed quality management system they are aware of the high expectations that are required from them and usually respond with meeting those high standards. 4.1 Management Responsibilities The AMC managing director has overall quality control for procedures planned, undertaken and reports written accordingly but the expeditor must own a sense of responsibility for the duty of car that he/she must take to:
• commence with the risk assessments in line with the MSDS and local circumstances; • proceed with operations to test the resource in a safe, healthy manner using best industry
practice with well-maintained and calibrated equipment to ensure a quality analysis • To collate and analyze the information before proceeding to write a full-detailed report
The AMC managing director will set out what is required from each report with guidelines on what sections need to be included and how the information was reached. 4.2 Resource Management This area controls the responsibilities of staff and expeditors and gives details of how people will be hired with detailed job descriptions and details of how the company will recruit staff. The methods of communications will be identified and the staff who are responsible for ensuring that the information is relayed. This area also identifies how AMC will procure equipment often depending on external pressures such as legislation, client controls and availability of spares and maintenance contracts. AMC management will write a user resource specification (URS) describing what the equipment is required to do, standards necessary for the equipment to comply and maintenance contracts required to satisfy the compliance. AMC will maintain stores with critical spares, personal protection equipment, measuring & monitoring equipment, or other apparatus which may be required to be sent to an expeditor in the field if their equipment fails to work.
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4.3 Resource Inspection Reports: A Resource Inspection report will give a detailed accurate account of the processes that led to conclusions found in analysing the hydrocarbon resource:
• Location, date, times, weather conditions • Ship’s crew, operations manager, project manager • Health and Safety procedures, COSHH, • Precautions taken to prevent pollution (loss minimization)
The report will be incorporated in the narrative script of the Expeditors report.
4.4 Measurement Analysis & Improvement
This part of the control management system describes how the product will be controlled through the various stages to ensure that the end result will be a product of quality.
At various stages of an Expeditor assignment, the general manager will expect to see evidence that the expected company quality standards have been maintained and met and that due care of the clients’ commercial interests are protected at all times before, during and after the operation.
• Receiving the job specifications from the client and checking for any clarification required • Ensuring instructions have been relayed clearly to expeditor and that the window for
resource inspection is secured with flight details arranged • When a risk assessment is completed in the site locality using the MSDS and detailing any
potential environmental concerns, • Complete checks to ensure equipment is in working order and calibrated if necessary. • Following operational procedures to retrieve information about the cargo resource, any
issues or reasons for not being able to carry-out procedure! • Proof read preliminary report detailing report requirements as stated above • Quality checks by general manager prior to sending final report to client.
By following the quality policy with its process, the final documents having been quality-checked throughout the progression, will result in a quality document, numbered and referenced clearly, ready for client scrutiny and audit control itemised as per clients’ specifications.
Signed by: Date:
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5.0 Environmental Planning
Before deciding how AMC will take action to reduce impacts on the environment, the aspects of the company will need to be determined to identify the impacts.
Environmental Aspect: Element of an organisation’s activities, products or services that can interact with the environment.
Environmental Impact: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s activities, products or services.
5.1 Environmental Aspects Analysis:
• Dusts • Noise/vibration
– high/low frequency – intermittent/impulse etc
• Odours • Water abstraction/consumption • Materials consumption
– process materials – raw materials (ores, etc ) – packaging – spares/consumables – maintenance/cleaning – contractors’ materials
• Energy consumption – electricity – gas – fuel oils – LPG/LNG etc.
• Visual intrusions – buildings/structures – lighting – accumulations – wastes/litter/etc
Aspects and Impacts will be evaluated using the template 2.1 in the appendices.
5.2 Legislation:
Compliance is an important part of AMC operations as expeditors work in various locations around the world and their procedures may infringe upon local legislation. As the UK Regulations and statutes have been based upon European Directives which are in turn derived from United Nations frameworks, it is prudent that AMC staff and contractors have a profound understanding about the legislation that affects them and their operations in the UK. This will enable them in their decision-making when they are overseas.
AMC will use template 2.2 in the appendices to determine which legislation is applicable to them and how it affects their operations.
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5.3 Objectives and targets:
For the IMS to be effective, we require specific, measurable, achievable targets for AMC key performance indicators. These targets are essential if AMC is to continually improve on its performance. This includes performance with regards to compliance, timely servicing of equipment and the quality of reports sent to the clients.
AMC will determine and set targets annually based on significant aspects and impacts and in line with AMC objectives.
For set targets see appendix
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6.0 IMS IMPLEMENTATION AND OPERATION
6.1 Structure and Responsibilities
Ultimate responsibility for all Quality, Health & Safety, & Environmental issues within the company rests with the AMC Managing Director. The company’s Management has the responsibility to ensure that attending Expeditors are made aware of their QHSE responsibilities and are held accountable for them.
The Managing Director has the responsibility for ensuring that the Expeditors follow best practice guidelines and that they are properly implemented and performed to requirements in all locations and spheres for which they are responsible.
New Expeditors must receive a copy of their job description during initial induction which will outline what is expected of them in terms of QHSE standards during their contract with AMC. The General Manager is responsible for ensuring that job descriptions are communicated to all Expeditors.
AMC will provide visible demonstration of the company’s commitments to all of its policies through:
• Inclusion as the first item on the agenda at management meetings • Involvement in assignments (2nd party) • Providing resources for corrective action where issues have been identified
6.2 Training And Competence:
The AMC General Manager must ensure that each expeditor is competent in Health, safety and environmental aspects and expectations must be described in detail as part of their job description in the Contractors Agreement Policy.
The competency required must be specific to the activities undertaken by the Expeditor. For example, someone responsible for the measurement of flammable cargo must have attended recent HS training courses and have had training that covers pollution control and emergency response procedures when dealing with flammable substances. Prior experience and training received must be documented for all company Expeditors. The General Manager is responsible for ensuring that the appropriate records are maintained, accurate and up to date. This will allow rapid verification and demonstration of personnel competency.
AMC will maintain a training and competence matrix which will consist of all training applicable for staff and contractors associated with AMC Operations. The training matrix will be made available to clients and auditors upon request. AMC will also keep copies of certificates and notify staff when training needs to be updated. AMC will complete form in the appendices.
6.3 Communications:
All new Expeditors must be made aware of the priority that the company gives to its QHSE during initial induction. Expeditors are expected to engage in proprietary safety awareness courses where this will enhance their HS awareness / performance.
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The General Manager will consult expeditors whenever QHS& E matters are reviewed or modified which should be undertaken via email and verbal communication. QHS& E information must be communicated to expeditors to promote understanding and participation. HSE Risk Assessments will be discussed with expeditors to evaluate whether further clarification is required and/or follow-up action is required.
Environmental Management is a partnership with our clients, sub-contractors and supply chains. If expeditors observe practices that they consider as a non-conformance such as a possible pollution problem, they are asked to consider new initiatives to solve the issue and report the situation so that an agreeable solution can be found to minimise risk and therefore loss.
6.4 Documentation
All documentation regarding the IMS will be identified clearly according to the quality management system standard operating procedure (SOP) Q100/01.
6.5 Emergency Preparedness and Response
As the resource being inspected will inevitably be hydrocarbons, an extremely flammable, explosive and highly toxic substance to humans, the expeditors will be well aware of the hazards and be reminded of exactly what the duty-holders for health and safety risks should assess!
The expeditor should understand the COSHH (Control of substances Hazardous to Health) 2002 regulation and the Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 (PFEER). In assessing and controlling the risks from hydrocarbons, and implementing emergency response procedures, duty-holders may deal with health and safety risks together, but the following paragraphs refer to the control of toxic risks.
’13. Exposure to hydrocarbon gases/vapours may result from a breach of plant integrity. This breach may be intentional (eg for sampling, maintenance, pigging etc) or accidental (eg leaks or plant failure).
14. An intentional breach of integrity is by its nature readily foreseeable, and the risk is easily assessed. Controls applied for preventing exposure vary according to the risk, but include de-pressurising, de-gassing, closed systems for sampling, local exhaust ventilation and the use of respiratory protective equipment.
15. The basic control of accidental failure is prevention, eg by plant and systems maintenance. If integrity is breached, control will depend on a predefined safe system of work that needs to consider the likely locations and nature of significant releases, the ease of escape, area alarms and personal alarms, training and the use of respiratory protection (escape kit).]
Knowing where significant releases may occur and what hydrocarbons they are likely to consist of
16. Duty-holders need to have carried out sufficient analysis of their systems which contain hydrocarbons to know those areas where significant concentrations could be released in the event of foreseeable faults/leaks in the system, process control errors, or process upsets, and the likely nature of the hydrocarbons present.
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The relevant legal requirements are:
• the Health and Safety at Work etc Act 1974; • the Management of Health and Safety at Work Regulations 1999 (SI 1999/3242 ,
regulations 3, 4, and 7; • the Control of Substances Hazardous to Health Regulations 2002 (SI 2002/2677 ),
regulations 6, 7, 8, 9, 12 and 13; • the Offshore Installations (Prevention of Fire and Explosion, and Emergency Response)
Regulations 1995 (SI 1995/743 ), regulations 5, 8 and 9; • the Confined Spaces Regulations 1997 (SI 1997/1713 ) do not apply offshore but, along
with the associated ACOP and guidance, they provide valuable advice where confined spaces present an additional risk.’ (Health and Safety Executive, 2012).
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7.0 CHECKING AND CORRECTIVE ACTION
7.1 Monitoring and Measurement
The company monitors QHSE performance using:
• Real time reporting of actual and potential safety matters during assignments either by telephone or email.
• Narrative reporting to the head office and passed onto the client. • Reporting and commenting on incidents and implementing, if possible at the time,
corrective action • Measuring and Monitoring of Performance through aspects and impacts register, training
matrix, risk assessments, RIDDOR, non-conformance records and quality control. • Maintain quantitative records of utilities: energy, water and waste
However, AMC’s preferred approach is to identify and address conditions that could lead to an incident prior to the incident occurring.
An incident is an event that can give rise to an accident that causes harm to people, the environment or property, or that has the potential to lead to such an accident. The term incident includes “near misses”. Incidents and the potential for incidents should be avoided. Where incidents do occur it is important that lessons are learnt to prevent reoccurrence.
If a HS incident or Environmental non-conformance occurs during any vessel, terminal, offshore location attendance, it must be:
• Reported • Recorded • Investigated • Corrective actions, suggested, implemented and recorded • Followed up
Findings on an incident will be communicated with a follow up showing corrective actions and finally, checking to ensure that the remedial actions have been effective and are working as intended.
Communications of findings include relaying the information so that corrective actions can be implemented throughout the company.
Template 2.4 – Accident / Incident Reporting form will be completed for near misses in addition to incidents occurred. The form also asks what remedial actions are / can be pursued.
Template 2.5 – Environmental Non-conformances and incidents will be completed using template 2.5. This also includes reporting on potential pollution issues.
All contracted Expeditors must be in possession of an Incident Reporting Form and an environmental non-conformance form during assignments or access to them electronically. The relevant incident reporting procedures must be communicated to new Expeditors during initial induction. The General Manager must ensure that all Expeditors are aware of the incident reporting procedures at commencement of work on the current project. Incident reporting procedures must take into account the requirements of applicable local regulations.
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The responsibility for ensuring that incident reporting procedures are followed is that of the attending Expeditor for all project-related incidents.
Any incident investigation must seek to identify the root cause of the incident, including failures of management, safety systems and the underlying reasons for human error. Ways of dealing with the root cause must be considered. Merely stating that personnel must try harder is not an acceptable outcome of an incident investigation.
7.2 Records and Record Management
All records that serve to demonstrate that this IMS has been implemented correctly and is operating effectively must be kept for a minimum period of five years or as required by local regulations. Records specifically required for compliance with local regulations must be marked accordingly as per SOP Q100/01.
The IMS forms and checklists will be kept together with the main body of the IMS in the Apex Marine Consultants Offices as stated on the front page.
Records for Hazardous Waste Consignment notes must be kept for 3 years.
Records for Waste Transfer Notes must be kept for 2 Years however these records can be scanned and kept in electronic files.
HS records will include:
• Records of Expeditors PPE, safety equipment maintenance including Personal Gas Monitors, Hard Hats, etc
• Risk Assessments and Method Statements • MSDS • Incidents • RIDDOR • Audit and inspection records • Personnel training and experience records
QHSE records must be available to the company’s personnel. No QHSE record must be disposed of without the written authority of the Managing Director.
7.3 Exclusions, Non-conformance, Prevention & corrective action
Exclusions to Apex Marine Consultants Services
a) Apex Marine is not involved in design. b) A.M.C. Does not possess any calibrated equipment c) A.M.C. does not calibrate equipment d) A.M.C. is not involved with structural inspections of vessels e) A.M.C. is not involved with inspections on aircraft. f) A.M.C. is not involved with vessel engineering. g) A.M.C. is not involved with vessel chartering h) A.M.C. is not involved with vessel brokerage. i) A.M.C. is not involved with vessel agency services j) A.M.C. is not involved with vessel freight.
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If a requirement of the AMC Integrated Management System is not met then it must be recognized as a ‘non-conformity’. Any non-conformance should be reported on the non-conformance form. A significant non-conformity such as a hazardous substance spill, then a formal investigation should occur to prevent a reoccurrence.
7.4 Evaluation of Compliance
Regular checks of compliance will be undertaken by the general manager who will always ensure risk assessments, site inspection and legislation has been observed throughout resource inspections. Observation will include monitoring the legislation template to ensure that it reflects current regulation (see references for links to websites containing relevant information).
7.5 Internal Audits
AMC QHSE audit Programme has been developed by the Managing Director. The objective of the QHSE audit programme is to monitor compliance with the company’s QHSE Policies, compliance with all relevant legislation and the detailed requirements of the IMS. It should take into account the findings of previous audits, inspections and incident investigations. The audit programme will detail specific audits to be carried out, the audit scope and the person responsible.
The responsible person must ensure that:
• The audit is carried out as required by AMC Audit Programme. Any specific local requirements must be included.
• Appropriate remedial action is taken where the audit identifies non-compliance with legislation or the requirements of the IMS.
• Principal findings of the audit should be acted upon immediately.
Persons carrying out the audits must be able to demonstrate competence for this function. An audit will be conducted annually with the audit programme reviewed regularly.
8.0 MANAGEMENT REVIEW
The Managing Director must review this IMS at least once every 12 months to ensure its continuing suitability, adequacy and effectiveness and to identify opportunities for further improvement. The review must take into account the company's sphere of operations, locations and anticipated activities during the next 12 months.
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9.0 TERMS AND DEFINITIONS
Accident Undesired event giving rise to ill health, injury, damage to the environment or property or other loss.
Audit Systematic examination to determine whether activities and related results conform to planned arrangements and whether these arrangements are implemented effectively and are suitable for achieving THE COMPANY's HSE policy and objectives.
Continual Improvement
Process of enhancing the HSE Management System to achieve improvements in overall HSE performance in line with the company’s HSE Policy.
Hazard Situation with a potential for injury, ill health, damage to the environment, damage to property or a combination of these.
Hazard Identification
Formal process of recognising that a hazard exists and defining its characteristics.
HS Health and Safety
Incident Event that gives rise to an accident or which had the potential to lead to an accident. The term incident includes near misses.
Journey Management Plan
A plan for a freight forwarding journey aimed at reducing HSE risks during the journey to tolerable levels
Port Operation Plan
A plan for the physical handling of either inbound or outbound materials and equipment in a Seaport or Airport environment
Vessel Husbandry Operation
The administrative requirements related to a marine craft’s call at a Seaport or designated marine terminal
(MSDS/SDS)
Non-conformance
Material Safety Data Sheet
Any deviation from work standards, practices, procedures, regulations, management system performance etc. that could either directly or indirectly lead to injury, illness, damage to the environment, damage to property or a combination of these.
(HS) Objectives
Defined HS performance that the company has set itself and aims to achieve.
Project HS Plan
A safety plan, were applicable, must be developed at the beginning of each project detailing safety requirements that must be fulfilled at each stage of the project (E.G. cargo tank entry)
Risk Combination of the likelihood and consequences of a specified hazardous event (incident).
Risk Assessment
Formal method for the systematic identification of HSE hazards, assessment of risks and development of appropriate control measures to ensure that the risk is tolerable.
Safety Freedom from unacceptable risk of harm (to people).
Site Office, warehouse, port or other facility owned or operated by the company or location where the company carries out their activities.
Apex Marine The company.
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Consultants
9.1 References:
IMS / Q100/ 00 Rev 1 – 11/14 Page 21
9.2 Appendices + Amendments / Additions to the I.M.S.
Notes :-
This 1st revision to the Integrated Management System was as a result of omissions highlighted in the 1st stage of ISO 9001 (2008) certification conducted on 27th November 2014 by John Knowles.
Revisions implemented – Addition of Exclusions in paragraph 7.3
