Proactive WSH Management

What is Proactive WSH Management
Proactive WSH management is all about resolving any issues before an incident or an accident occurs.

Example of Proactive safety measures include:

• Conduct monthly WSH Inspections
• Conduct internal / external Audits
• Monitoring of WSH performance
• Monitoring of WSH behaviour
• Risk Assessment Review
• WSH Training
• HSE reporting - reporting on unsafe condition and unsafe behavior

The benefits of a proactive WSH management are that it will instill and inculcate a positive safety mindset and help to prevent accidents from occurring.

Reactive WSH Management
Reactive WSH management is about dealing with issues following an incident/accident 

In this post i am going to share with you free online resources to create HSE reporting using Google Workspace -Google Form 

• Sign up for google account
• Navigate to Form
• Start designing your HSE reporting form

The HSE reporting form which i am going to create entrust the department head to follow up on the corrective actions following the HSE reporting made by their employees to create the proactive HSE management approach.

Upon receipt of the HSE report being made through the system, it will notify me ( Google form author)  on the safety lapses raised since the Google HSE reporting was created using my own Google account and non transferrable.

Here is the HSE reporting template

And here is the HSE reporting statistics in your google form dash board where you can view and print out or even download in excel sheet for your analysis.

CheckSafe - Check company WSH performance

Having difficulties to qualify contractors and suppliers ? And cannot make the decisive decision between cost and work quality? Here is the solution. 

Use free and credible online resources from the Singapore Ministry of Manpower CheckSafe to check external parties WSH Performance.

Through this portal you can compare Companie's workplace safety and health performance easily.

Here are what you can expect

• You can use CheckSafe to help you make more informed choices of contractors and partners based on their WSH performance.
• You’ll be able to see info such as:

1. Injury data e.g. number of fatal injuries.
2. Enforcement data.e.g. stop work orders, demerit points issued, placement on Business Under Surveillance (BUS) Programme, conviction records

• List of contractors with demerit points

Why can’t I find the records of my company or a specific company in CheckSafe?
The calculator will return you with records if the firms have these data fields in the last 3 years:

• Fatal cases
• Work Injury Compensation (WIC) Permanent Injury cases 
• Stop Work Order
• Demerit Points (for Construction companies)
• Business Under Surveillance
• Workplace Safety and Health Act (WSHA) Conviction Records
• WSH and bizSAFE Awards

Companies that are on the bizSAFE programme, but do not have records in any of the fields listed above, will not be shown on CheckSafe.

How often is CheckSafe updated?
CheckSafe data is updated every 2 weeks

How many years of data can I see in CheckSafe?
You can view up to 3 years of data

To learn more check out MOM CheckSafe - Check Company WSH performance MOM Website.

WSH Professionals should use the MOM CheckSafe tools to make more informed choices of service providers or partners based on their WSH performance.

And here is the screenshot guide to help you 

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CP CEO WSH Duties

The Code of Practice on Chief Executives and Board of Directors WSH Duties was published on the Government Electronic Gazette on 14 October 2022 which comes into force from 31 October 2022.

The objective of the CP is to provide clarity on and strengthen ownership of companies’ Chief Executives’ and Board of Directors’ (henceforth termed as “Company Directors”) workplace safety and health (WSH) roles and duties.

Chief Executives and Board of Directors are usually the ones behind the scene steering the operations and oversee management of their organisation and have greater influence and authority over their workplace safety and health (WSH) standards.

The CP called for Company Directors to prioritise  workplace Safety and health and set the safety culture for their organisations as stipulated in Section 48(1) of the Workplace Safety and Health Act .

This Code of Practice provide greater clarity on and strengthen WSH ownership of Company Directors and also lists available resources that can aid Company Directors in their efforts to discharge their duties and uphold WSH standards at their workplaces.

Here are  the 7 Principles and 17 Measures to Guide To Uphold Workplace WSH Standard 

ISO Clause 9.3 Management Review

 ISO clause 9.3 Management Review

The management review process requires Top Management to periodically review the the organization ISO Management System to ensure its continuing suitability, adequacy, and effectiveness while addressing the possible need for changes to quality, environment, safety and health policy, objectives, targets and other elements of the Management System.

The Management Review Team shall comprise of the General Manager, Managers and key Supervisors. The General Manager is present at the meeting to assess the suitability, adequacy and effectiveness of the Management System.  The various Managers & key supervisors provide inputs such as reports and analysis charts according to the set meeting agenda. The Senior Manager organizes and co-ordinates the management review meeting.

How Often Should We Schedule A Management Review?

ISO 9001/45001/14001 Management Review should be conducted at least once a year and before the scheduled external audit. Some organization may conduct it either six monthly or quarterly. It depends very much on the organization requirement.

I personally opined the Management Review should be conducted twice over six months to be able to monitor the action item effectively.

Here is the ISO clause 9.3 management review comparison

And here is the management review outputs example

Workplace Safety, Workplace Health Resources Blog: NEA Nonylphenol Regulation

Workplace Safety, Workplace Health Resources Blog: NEA Nonylphenol Regulation: Effective 01 Mar 2023, 5 new chemicals will be controlled as Hazardous Substances by the National Environment Agency (“NEA”) under the Envir...

Workplace Safety, Workplace Health Resources Blog: NEA Nonylphenol Regulation

Workplace Safety, Workplace Health Resources Blog: NEA Nonylphenol Regulation: Effective 01 Mar 2023, 5 new chemicals will be controlled as Hazardous Substances by the National Environment Agency (“NEA”) under the Envir...

NEA Nonylphenol Regulation

Effective 01 Mar 2023, 5 new chemicals will be controlled as Hazardous Substances by the National Environment Agency (“NEA”) under the Environmental Protection and Management Act (“EPMA”) and Environmental Protection and Management (Hazardous Substances) Regulations (“EPM(HS) Regs”).

The chemicals are:

• Amitrole;
• Nonylphenol and Nonylphenol Ethoxylates;
• Iprodione;
• Dechlorane Plus; and
• UV-328 2

A Hazardous Substances Licence will be required for companies that import, sell, export and manufacture these chemicals, while end-users that purchase, store and use these chemicals will be required to obtain a Hazardous Substances Permit.

Harmonized System (“HS”) and Product Codes 3 The list of HS and Product Codes can be found in ANNEX A. With effect from 1 Mar 2023, traders are required to use the appropriate HS and Product Codes when declaring their import and export TradeNet® permit applications.

All such TradeNet® permit applications will be subject to Chemical Control and Management Department (CCMD)’s processing and approval. 4 For more information on the control of Hazardous Substances, please visit NEA website at: https://www.nea.gov.sg/our-services/pollution-control/chemicalsafety/hazardous-substances/management-of-hazardous-substances. 5 For further enquiries on TradeNet® matters, you may e-mail them to nea_pcd_hs@nea.gov.sg

Control of 26 Hazardous Substance

Singapore's National Environment Agency (NEA) is proposing to regulate 26 new chemicals and chemical groups (see Section 4 above) as hazardous substances under the Environmental Protection and Management Act (EPMA) and the Environmental Protection and Management (Hazardous Substances) Regulations (EPM (HS) Regs).

These 26 chemicals and chemical groups have been identified as toxic chemicals and precursors under the Chemical Weapons Convention (CWC), and are currently regulated by Singapore Customs, as the National Authority for the Chemical Weapons Convention (NA(CWC)), through the Chemical Weapons (Prohibition) Act (CWPA) and the Chemical Weapons (Prohibition) Regulations. Under the CWPA, depending on the CWC Schedule that the chemicals belong to, companies are required to apply for a NA(CWC) licence from Singapore Customs if they are engaged in activities including the import, export, production, processing, consumption and local sale and distribution of these chemicals.

From July 2023, NEA will also be regulating these 26 chemicals and chemical groups under the EPMA and EPM (HS) Regs. Once the regulations take effect, companies will be required to apply for a Hazardous Substances (HS) licence/permit from NEA for the import, export, manufacture, sale, transport, storage and/or use of these chemicals and of products containing these chemicals. Accordingly, companies engaged in activities involving any of these chemicals would have to comply with the requirements on the import, export, manufacture, offer for sale, transport, storage and/or use of hazardous substances, that are stipulated in the EPMA and EPM (HS) Regs. These include, inter alia, labelling and other requirements for the containers/tanks and vehicles that are used to store or transport the chemicals, as well as other specific safety and documentational requirements.

Here are the 26 chemicals and chemical groups

For more information, kindly refer to NEA website.

Workplace WSH Hazards

WSH HAZARDS ASSOCIATED WITH THE WORKPLACE

INTRODUCTION

Company XXXX is the world leading manufacturer of polymeric medical grade components and systems for injectable drug delivery, including stoppers, seals for vials, and closures.

Its business operations mainly served the hospital, healthcare and pharmaceuticals industries. In view of Company XXXX varying customer’s products requirements, it employ substantial amount of both hazardous and flammable chemicals in it’s manufacturing operations

At it’s facility located at YYYY, Company XXXX risky installation sites include:

Steam Boiler

Air Receiver

Chemical Liquid Store

Flammable Liquid Store.

Toxic Industrial Waste Storage

Substantial amount of hazardous and flammable substances were stored and used in Company XXXX manufacturing operations which require both a hazardous substance permit and Petroleum and Flammable Material Storage license.

To comply with the National Environment Agency , the Environmental Protection and Management Act, Section 26, Company XXXX have to conduct pollution/hazard/risk impact studies on its hazardous installations and this include both the chemical liquid store ,flammable liquid store and toxic industrial wastes storage.

The purposes of the QRA are to:

·        identify and quantify hazards and risks related to the transport, use and storage of hazardous materials;

·        determine hazards/risks due to possible accident scenarios which will lead to fire, explosion or toxic release;

·        recommend measures to be incorporated in the design and operation of the plant to keep hazards/risks to as low a level as practical;

·        facilitate the development of emergency response plans to deal with all possible accident scenarios

 

In view of Company XXX manufacturing requirement, it is prone to both chemical and physical hazards due to significant amount of hazardous substances and flammables employed in their manufacturing operations as well as the use of lifting equipment, gears, appliances , utilities such as the steam boiler, air compressor and air receiver to power it’s utility

IDENTIFY CHEMICAL HAZARD

To identify the chemical hazards, Company XXX should consider the use of   QRA, where key elements of risks, such as the statistically expected frequency of an accident and the statistically expected consequences of exposure to a toxic gas, must be determined using  these  probabilistic variables.

QRA is an approach for estimating the risk of chemical operations using probabilistic information. And it is fundamentally different approach from those used in many other engineering activities because interpreting the results of QRA requires an increased sensitivity to uncertainties that arise primarily from the probabilistic character of the data

Estimating the frequencies and consequences of rare accidents is a synthesis process that provides a basis for understanding risk. Using this synthesis process, we can develop risk estimates for hypothetical accidents based upon our experience with the individual basic events that combine to cause the accident. System logic models are used to couple the basic events together, thus defining the ways accident can occur

IDENTIFY BIOLOGICAL HAZARD

When considering hazards from pathogenic bacteria, however, a qualitative risk assessment may be the only feasible method currently available to derive an assessment of the severity and the likelihood of harm associated with exposure through ingestion of a food. However, both the quantitative and qualitative methods will depend on the type and quality of information developed during the risk assessment process.

While the basic steps are the same, their application will be different when conducting a qualitative assessment, as the analyst will not have the information necessary to develop a mathematical estimate of the probability and/or severity of an adverse consequence. When assessing risk for some biological agents, sufficient data may be available to conduct a quantitative analysis. However, the analyst will find that in most cases the many uncertainties associated with how and when an organism may express pathogenic potential will make a quantitative assessment impractical. Further research is required to permit more accurate and quantitative assessments in the future.

In the absence of quantitative data to develop an exposure assessment, measurement of hazard levels at particular process steps, or segments of the production chain, may provide a qualitative indication of likely risks to consumers. In this respect comparative studies on biological hazard levels and qualitative estimates of the likely effects of differences to human health can be used.

The analysis of risk associated with bacterial pathogens presents unique challenges. Any method used to assess the risk of hazards from food borne bacteria will be complicated by factors resulting from methods used to grow, process, store and prepare food for consumption. These can vary greatly depending on cultural and geographical differences. Such factors describe the scenario set for a given food and are an essential element in a risk assessment for bacterial hazards.

As already noted, in many cases sufficient data will not be available to support a quantitative assessment of risk associated with pathogenic bacteria. The following present an indication of the type of challenges that make quantitative risk assessment difficult for pathogenic bacteria associated with foods.

Bacterial agents known to cause food borne disease have been identified by using epidemiological and other data to link the organism and its source to illness. However, as only a limited number of outbreaks are adequately investigated, it is likely that a number of bacterial pathogens in food remain to be identified.

Limitations on hazard identification include (i) the expense and difficulty involved in outbreak investigations; (ii) the lack of reliable or complete epidemiological data; and, (iii) the inability to isolate and characterize new pathogens

RA Technique

IDENTIFICATION OF INDUSTRIAL HAZARDS WITH RISK ASSESSMENT TECHNIQUE

There are many risk assessment technique available in the industry which can be used to identify industrial hazards. Below outlined the various techniques that can be used to identify hazards and provide a brief overview of their advantages and disadvantages.

It should always be remembered that any system or operation comprises:
people, procedures, equipment and an environment of operation

All these elements must be considered during hazards identification.

Risk Assessment Technique for Identification of Industrial Hazards

What-if analysis

Hazard and Operability Study (HAZOP)

Fault Tree Analysis

Event Tree Analysis

Failure Mode and Effects Analysis

Job Safety Analysis

In this post, only the following techniques will be explained

HAZARD AND OPERABILITY STUDY (HAZOP)

HAZOP is a systematic and structured approach using parameter and deviation guidewords. The technique relies on a very detailed system description being available for study and usually involves breaking down the system into well defined subsystems and functional or process flows between subsystems. Each element of the system is then subjected to discussion within a multidisciplinary group of experts against the various combinations of the guidewords and deviations.

The group discussion is facilitated by a Chairman and the results of the discussion recorded by a Secretary together including any hazards identified when a particular guideword and deviation combination is discussed. Where a particular guideword and deviation combination does not produce any hazards, or is not though t credible, this should also be recorded to demonstrate completeness.

The guidewords and deviations must be prepared in advance by the HAZOP Chairman and may need to be tailored to the system or operation being studied.

In an aviation context, typical guidewords might include:

Detection

Co-ordination

Notification

Transmission

Clearance

Authorisation

Selection

Transcription

Supervision

Typical deviations might include:

Too soon / early

Too late

Too much

Too little

Too high

Too low

Missing

Twice / repeated

Out of sequence

Advantages of Hazard and Operability Study

Systematic and rigorous.

Involves interaction of views from multidisciplinary experts.

Can be applied to a wide range of types of system.

Creates a detailed and auditable record of the hazards identification process.

Disadvantages of Hazard and Operability Study

Requires a considerable amount of preparation.

Can rely heavily on the skills of the HAZOP Chairman

Can be time consuming and therefore expensive.

Can inhibit imaginative thinking and so certain kinds of hazards.

FAILURE MODE AND EFFECT ANALYSIS.

FMEA is a ‘bottom up’ technique that is used to consider ways in which the basic components of a system can fail to perform their design intent. This could either be at an equipment level or at a functional level. The technique relies on a detailed system description and considers the ways in which each sub-component of the system could fail to meet its design intent and what the consequences would be on the overall system. For each sub-component of a system an FMEA considers:

All the potential ways that the component could fail.

The effects that each of these failures would have on the system behaviour.

The possible causes of the various failure modes.

How the failures might be mitigated within the system or its environment.

Behaviours at the system level arising from the sub-component failures which have a safety consequence are thus identified as hazards. The system level at which the analysis is applied can vary and is determined by the level of detail of the system description used to support the analysis. Depending on the nature and complexity of the system, the analysis could be undertaken by an individual system expert or by a team of system experts acting in group session.

Advantages of FMEA

Systematic and rigorous.

Creates a detailed and auditable record of the hazards identification process.

Can be applied to a wide range of types of system.

Disadvantages of FMEA

Only really considers hazards arising from single point failure modes rather than combinations of failures.

Relies on people with detailed system knowledge.

Can be time consuming and expensive

WHAT IF

What If is developed as a simpler and more efficient alternative technique to HAZOP
Like HAZOP, What If involves a multidisciplinary team of experts under the facilitation of a Chairman. It is a facilitated brainstorming group activity but is typically carried out on a higher level system description , having fewer sub elements, than for HAZOP and with a reduced set of prompts.

Ahead of the group session the Chairman prepares a suitable list of prompts such as:

What if...?

Could someone...?

Has anyone ever...?

The Chairman uses the prompts to initiate discussion within the group.

Advantages of What If

Creates a detailed and auditable record of the hazards identification process.

Is less time consuming than other systematic techniques such as HAZOP.

Disadvantages of What If

Careful thought is required in preparation for the application of the technique.

Relies heavily on the expertise and experience of the team members.

Relies heavily on the skills of the Chairman

 

RA Limitation

Limitation in Risk Assessment

When using the QRA results for decision making purposes or when chartering a QRA Study, we must recognise and respect the limitation in risk assessment due to the fact that quantitative risk analysis is subject to several theoretical limitation lists.

Completeness	There can never be a guarantee that all accident situations, causes, and effects have been considered
Model Validity	Probabilistic failure models cannot be verified. Physical phenomena are observed in experiments and used in model correlations, but models are, at best, approximations of specific accident conditions
Accuracy/Uncertainty	The lack of specific data on component failure characteristics, chemical and physical properties and phenomena severely limit accuracy and can produce large uncertainties
Reproducibility	Various aspects of QRA are highly subjective-the results are very sensitive to the analysts assumptions. The same problem, using identical data and models, may generate widely varying answers when analyzed by different experts
Skill Unavailable	The accuracy and corresponding uncertainty of a risk estimate depend heavily upon the expertise and judgement of the analyst
Inscrutability	The inherent nature of QRA makes the results difficult to understand and use

RA key Elements

KEY ELEMENTS OF RISK ASSESSMENT

Risk assessment is the scientific process of collecting and analysing scientific data to describe the characteristic of risk which can take up many forms such as physical hazard, mechanical hazard, chemical hazards and biological hazards etc.

Every workplace should conduct risk assessments for all routine and non-routine operations carried out under various environmental situations, e.g., weather and soil conditions. Routine operations include activities such as preparatory and troubleshooting work activities. Non-routine operations include commissioning, repair and maintenance of plants

There are many risk assessment methods available in the industry and the choice of method depends very much on the purpose and scope of the available information or data used in an assessment as well as what we want to achieve at the end of  a risk assessment study

No matter which methods of risk assessment that you use, all methods should comprise the 3 basic steps of ; Hazard Identification, Risk Evaluation and Risk Control..

Hazard Identification is the process of identifying hazards in order to plan for, avoid, or mitigate their impacts and for decision making purposes.  Hazard identification is an important step in risk assessment and risk management

Hazard identification builds the foundation on which subsequent quantitative frequency and/or consequence estimates are made. We may have considered chemical, physical, mechanical and biological properties can present a hazard during a fault or failure conditions. But it is not always possible to be sure that all situations have been taken into consideration.

The simplest systematic approach to identify hazard is the use of checklist. Checklists are lists of known hazards or hazard causes that have been derived from past  experience. The past experience could be previous risk assessments of similar systems or operations, or from actual incidents that have occurred in the past. This technique involves the systematic use of an appropriate checklist and the consideration of each item on the checklist for possible applicability to a particular system.

Checklists should always be validated for applicability prior to use. 

Advantages of using checklist to identify hazard

They can be used by non-system experts.

They capture a wide range of previous knowledge and experience.

They ensure that common and more obvious problems are not overlooked.

Disadvantages of using checklist to identify hazard

They are of limited use when dealing with novel systems.

They can inhibit imagination in the hazards identification process.

They would miss hazards that have not been previously seen.

Consequence Analysis

Consequence Analysis is the process of examining the possible effects of a planned activity, for example the possible risks to the environment that may be caused by building work

Consequence analysis involves 4 basic activities which include:

• Characterizing the source of the release of material or energy associated with the hazard being analyzed
• Measuring through costly experiments or estimating using models and correlations the transport of the material and/or the propagation of the energy in the environment to a target of interest
• Identifying the effects of the propagation of the energy or material on the target of interest
• Quantifying the health, safety ,environmental, or economic impacts on the target of interest

Risk Analysis

Risk Analysis is a component of risk management, it consists of

(1) Identification of possible negative external and internal conditions, events, or situations,

(2) Determination of cause-and-effect (causal) relationships between probable happenings, their magnitude, and likely outcomes,

(3) Evaluation of various outcomes under different assumptions, and under different probabilities that each outcome will take place,

(4) Application of qualitative and quantitative techniques to reduce uncertainty of the outcomes and associated costs, liabilities, or losses.

Successful QRA provide data and information that allow us to increase our wisdom and understanding of the risk of a particular activity.

To interpret the QRA results would require us to review the analysis objectives For example if our objective is to identify the most important contributors to potential accidents, then the results may be completely unsuitable for presentation to zoning commission interested in the total risk of a toxic material release.

Hence it is important and essential that QRA be interpreted only in the context of the study objective.

Four essential area largely determine our success in capitalizing on high quality QRA results and they are namely;

• Presenting the results in perspective
• Recognising the factors that influence perceptions of the meaning of the results
• Credibly communicating risk information in the public arena
• Avoiding common pitfalls in using the results for making the right decision

Principle Of Product Stewardship

Products and/or services of the organization 

Background

Company XXX is a global manufacturer of polymeric medical grade components and systems for injectable drug delivery, including stoppers and seals for vials, and closures for the healthcare industry.

In view of Company XXX product manufacturing requirements, substantial amount of flammables and hazardous substances were employed in Company XXX operations where this emergency response plan is developed to mitigate the consequences and severity of the foreseeable emergency situations applicable to Company XXX  

Identification of relevant principle of product stewardship in accordance with Company XXX Organizational Procedures

The International Council of Chemical Associations define Product Stewardship as the practice of making health, safety and environmental protection an integral part of the life cycle of chemicals

It is an integral component of the global chemical industry’s Responsible Care® initiative and includes evaluations of risks and the development of actions to protect human health and the environment commensurate with those risks

Product stewardship is a shared responsibility between chemical producers, their suppliers and their customers. It requires the development of close working relationships with suppliers, customers, and others in relevant value chains

The close relationships enabled these parties to share information up and down the value chain to ensure that chemicals are used and managed safely throughout their life-cycle. 

And by doing so, they will also help companies and their partners meet the increasing demand for safe and environmentally-sustainable uses of chemicals.

The benefits of Product stewardship are; it can provides the platform for companies to identify risks at an early stage and manage those risks along the value chain, thereby enabling adequate protection of human health and the environment.  This can result in increased customer loyalty as well as expand the positive impact of product stewardship down the value chain.

Evaluation and avoidance of risk reduces the potential for harm and potential liabilities, making product stewardship a “value added” business proposition

The relevant principles of product stewardship applicable to Company XXX include:

• Responsible and pro-active management of the environmental ,health and safety aspects of products throughout their entire life cycle;
• Compare and contrast relations with sustainable development, and corporate social responsibility;
• Life-cycle considerations for products;
• An integrated business process involving all, not just a team of specialists;
• Systematic management of risk at the earliest opportunity in an alert, pro-active, interested and open fashion;
• A commitment to continually improve EHS performance of its operations;
• Open communications with interested parties;
• A means of competitive advantage;
• Strategic differentiation, leading to enhanced reputation with the authorities, customers, employers and the community at large;
• Minimize product liability and likelihood of severe adverse issues or publicity

However, in this post, i will briefly explained the principles associated with responsible and pro-active management of the environmental ,health and safety aspects of products throughout their entire life cycle and a commitment to continually improve EHS performance of its operations

Responsible and pro-active management of the environmental, health and safety aspects of products throughout their entire life cycle

This principle require the top management commitment in the reduction of the environmental, health and safety impacts of products throughout their entire life cycle, which would requires a thorough life cycle assessment from manufacture of parts and products to transport, use by customers (e.g. reduced power consumption) and final disposal.

A system has to be established to clarify the environmental, health and safety impact of products throughout their life cycles. This include tracking the total life cycle costs such as the costs of purchasing, transporting, storing, treating and disposing of materials, the loss of man hours and loss workdays due to recordable injury recorded as well as the compensation to employees for their occupational diseases arising from work and the insurance premiums paid by the organizations under the Work Injury Compensation

Collection of information relating to number of occupational diseases as well as the number of recordable injuries rate reported in the manufacturing site as well as the CO2 emissions and energy and resource consumption at each stage of the life cycle

With the availability of these information, it would enables Company XXX to identify products and stages with high environmental, health and safety impacts, clarify improvement priorities and prepare the HSE goals, objectives and targets. And this would in turn assist WPSS  to monitor the environmental, health and safety impact of all its products.

A commitment to continually improve EHS performance of its operations

This principle would require the top management leadership and accountability to ensure it’s business units commitment and involvements to continually improve EHS performance of it’s operations which include:

• Management demonstrates that EHS issues rank amongst the highest priorities and maintains a commitment to continuous improvement.
• Business units to defines its Product Stewardship plan with appropriate targets and performance measures which are reviewed at least annually to maintain continuous improvement. Performance measures are broken down to annual employee target setting.
• Establishment of appropriate systems and procedures to manage EHS risks throughout the product life cycle, collecting information on the product's EHS hazards, assessment of employee and Customer EHS exposure
• Provision of training to employees and customers where the training scope may include the job function, with the objective of safe development, manufacture. storage, handling, transport, use and disposal of products.
• Communicate openly and honestly with employees and the public and be anticipative and responsive to their concerns about the potential hazards and impacts of products.
• Enforce the application of the Product Stewardship principles to all organization activities and to comply with all local EHS legislation and participate proactively in the development of local laws and regulations in all countries in which the Company has business activities