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Legislative
Review
The
legislative review aims to help the client meet the requirements of
4.3.2 (Legal & Other Requirements) of the EHS Management
Standards.
From ISO 14001:2004 -
4.3.2
Legal and other requirements
The organization shall establish,
implement and maintain a procedure(s)
a)
To identify and have access to the applicable legal
requirements
and other requirements to which the organisation subscribes related to its
environmental aspects, and
b)
To determine how these requirements apply to its
environmental aspects.
The
organization shall ensure that these applicable legal requirements and
other requirements to which the organization subscribes are taken into
account in establishing, implementing and maintaining its environmental
management system.
From OHSAS 18001:2007 -
4.3.2
Legal and other requirements
The
organization shall establish, implement and maintain a procedure(s) for
identifying and accessing the legal and other OH&S requirements
that are applicable to it.
The
organization shall ensure that these applicable legal requirements and
other requirements to which the organization subscribes are taken into
account in establishing, implementing and maintaining its OH&S
management system.
The organization shall keep this
information up-to-date.
The
organization shall communicate relevant information on legal and other
requirements to persons working under the control of the organization,
and other relevant interested parties.
The
LAW module of enviroMANAGER
allows the client to assess relevant legislation on the basis of a
“profile” and then provides constant updates as
legislation
changes.
Typically during implementation Scannell Solutions helps the client to
set up the profile and to populate the “Relevance”
field
against each Checklist (Legal Requirement).
Over time this needs to be kept up to date because of (a) changes to
legal requirements and/or (b) changes to the client’s profile
(activities, materials or equipment used, etc).
The review is carried out by a Scannell Solutions Consultant together
with relevant client staff and is intended to review the relevance of
new or amended legislation to the client’s operations and
record
this in enviroMANAGER.
Actions arising from the review are highlighted.
Such reviews can be carried out quarterly (as each update of legal
content is released) or annually.
Compliance
Audits
The
compliance audit aims to help the client determine how effectively it
is meeting the requirements of 4.5.2 (Evaluation of Compliance) of the
EHS Management Standards. It may also help to satisfy corporate audit
requirements.
From ISO
14001:2004 & OHSAS 18001:2007 -
4.5.2
Evaluation of compliance
4.5.2.1
Consistent with its commitment to compliance [see 4.2c)], the
organization shall establish, implement and maintain a procedure(s) for
periodically evaluating compliance with applicable legal requirements
(see 4.3.2).
The
organization shall keep records of the results of the periodic
evaluations.
NOTE: The
frequency of periodic evaluation may vary for differing legal
requirements.
4.5.2.2
The organization shall evaluate compliance with other requirements to
which it subscribes (see 4.3.2). The organization may wish to combine
this evaluation with the evaluation of legal compliance referred to in
4.5.2.1 or to establish a separate procedure(s).
The
organization shall keep records of the results of the periodic
evaluations.
NOTE: The
frequency of periodic evaluation may vary for differing other
requirements to which the organization subscribes.
Evaluation
of compliance is intended to determine:
a)
Who is responsible for checking compliance with a requirement
b)
When checks are carried out
c)
How compliance is determined
d)
What happens in the case of non-conformance
The
scope of the audit covers all legal Environmental, Health &
Safety
requirements in relation to European Community & National
legislation, along with any Permits and/or Licenses required by law.
It may also include Corporate or Other Requirements.
One or more consultants from Scannell Solutions will undertake the
audit on-site over an agreed period.
The audit is conducted through the use of physical inspections,
employee interviews and document/record reviews and is reflective of
conditions at the time of the on-site visit.
The effectiveness of closure of actions from any previous audit will be
reviewed.
There will be an opportunity for the overall audit and major findings
to be discussed with Management at a close out meeting.
The output of the exercise is a report which lays out the findings of
the audit, although this should not be interpreted as a guarantee of
compliance with all applicable and relevant EHS legal obligations.
Findings will be categorised as follows:
HIGH
RISK – Findings requiring immediate corrective action
indicating
non-compliance or potential non-compliance with a Statutory Regulation
culminating in death or serious injury to human life and/or a serious
contamination of the environment
MEDIUM
RISK - Findings also requiring a corrective action as they signify a
breach or a potential breach of a Regulatory requirement but where such
a breach is not considered to have a significant impact, either to
human life, health or the environment
LOW
RISK- Findings that are showing evidence of control from a Regulatory
standpoint but may be areas of improvement to be
considered
COMMENTS
– Relevant comments about
aspects of the EHS Management System
EVIDENCE
OF COMPLIANCE – areas where there was evidence of compliance
with relevant legislation
The report may be used to identify appropriate corrective actions and
Scannell Solutions may provide help with these as a separate project.
The “Evaluation of Compliance” field of the LAW Module of
enviroMANAGER will be updated to take account of the audit.
The Audit and non-conformance or recommendations may also be recorded
in the enviroMANAGER
AUDIT & INCIDENT modules.
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