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SOP for Environmental Aspect and Impact Identification

1.0

OBJECTIVE
To establish and maintain a procedure for identification of environmental aspects of the
organizations activities and products in order to determine those which may have a
significant impact on the environment.

2.0

SCOPE
This procedure is applicable to all the activities carried out in the organization. Procedure
explains the details of the methodology followed for the following activities:

3.0

Baseline evaluation or initial screening carried out initially

Follow up evaluation to be carried out periodically

Need for evaluation arising due to changes in legal requirements

Need for evaluation arising due to changes in product, process or activities.

RESPONSIBILITY

Identification of Aspects and Impacts EMS Core Team Members

Analysis of Aspects and Impacts and rating the same EMS Core Team Members

Determination of Significant Aspects and Impacts Respective HODs/ EMS Core


Team/ EHS Manager / Plant Head

4.0

ACCOUNTABILITY

Overall accountability for effective implementation of this procedure lies with


Management Representative assisted by EHS Manager.

5.0

PROCEDURE

5.1

Overview of Environmental Aspect Identification

5.1.1

This procedure covers those environmental aspects of activities and products that the
organization can control or over, which it can be, expected to have an influence. Significant
environmental aspects identified through this process are considered in the setting of
environmental objectives and targets.

5.1.2

The procedure consists of an initial screening of activities and products based on available
data by a cross-functional team of organization personnel. The cross-functional team
assesses the environmental aspects, determines which of these might result in significant
impacts, then sets priorities for further analysis, as needed.

5.1.3

The management team reviews the information developed during the evaluation on a
regular basis to ensure that it up-to-date.

5.2

Initial Screening or Baseline Evaluation:

5.2.1

Initial screening or baseline evaluation is carried out whenever a new process is set up and
during the initial implementation of IQEMS in the organization.

5.2.2

The initial screening is carried out in each of the stages in the life cycle of the organizations
products and other activities, including (where appropriate):

5.2.3

Process Development,
Production,
Storage/ packing, and
Disposal/waste management.
Maintenance

Management Representative along with EHS Manager and EMS Core Team Members
conduct a review meeting to perform the evaluation of all activities and products.

5.2.4

The team for the meeting includes Section Incharges or Representatives from Process
Development, Production, Packing and Stores Environmental, Health & Safety, or other
functions as appropriate.

5.2.5

Core Team brainstorms each activity / task involved in each stage of production or other
activities is evaluated for its environmental aspects and impacts in each of the departments
or sections with the help of EHS Manager and MR. Steps involved in Environmental Aspect
are as follows:

Identify the activity/ task in each process.


Identify the Aspects associated with those activities/ tasks.
For each aspect, identify the potential impact on environment, flora & fauna, people.
Determine the Condition and Type of Impact as below:
Normal Normal working condition
Abnormal - Any condition which is not being complied with

5.2.6

Emergency - an unforeseen or sudden occurrence, esp of a danger

demanding immediate remedy or action


Direct Direct Impact on Environment
Indirect Indirect Impact on Environment

In case an Aspect of the activity has an Emergency impact, the same shall be addressed in
the Emergency Preparedness.

5.2.7

For each aspect and impact, EMS Core Team rates the same as described below:

Each aspect and impact identified shall be given a rating on the parameters such as
Quantity, Occurrence, Impact, Legislation, Control and Detection as per the scale

described in the tables given below.


Quantity Quantity score indicates the physical quantities involved in the activity
ranging from 1 to 4 as below:

Quantity
Scale
Quantities causing major damages to resources,
4
people, plants and animals, plants and animals
Quantities causing major damage to resources but no
3
harm to people, animals and plants
Low quantities within permissible levels
2
Negligible quantities
1
Occurrence Occurrence score indicates the frequency of occurrence of the impact
based on the experience of the team. This rating ranges from 0 to 10 as below:

Occurrence (Frequency)
Scale
Continuously
10
once per shift
9
once per day
8
Weekly
7
Monthly
6
Quarterly
5
semi-annually
4
Annually
3
once every 1 to 5 years
2
over 5 years
1
Never
0
Impact Impact score indicates the severity of the consequence of the impact of the
respective aspect. This rating ranges from 0 to 10 as below:

Impact
Scale

Human
Impact

Animal / Plant
Effect

Impact on
Weather
Condition

Public
Relations

10

multiple
deaths

widespread
permanent
destruction

Ozone Layer
Depletion

single death

on-site
permanent
destruction

Global Warming permanent


public disfavor

disabling
injury

widespread
genetic impact

interrupted
operations

Major usage of natural


resources

long term
health
effects

on site genetic
impact

loss of historical
assets

lost time
Injury/
Illness

wide spread
disfigurement

pollution
impacting
surrounding
flora and fauna

state or national
protest

Major damage
requiring
reconstruction of the
structure and
equipment
Permissible levels of
natural resource usage

restricted
duty

on-site
disfigurement

local land
pollution

city or county
protest

Damage to Equipment
and Building

medical
only

wide spread
appearance

employee
protest

Minor natural resource


waste

first aid
treatment

reduction of
natural beauty

public
inconvenience

Usage of renewable
natural resource

Discomfort

on-site
appearance

public disfavor

None

None

none

None

None

None

plant closure

Consumption of
Natural Resources
and Property Damage
Consumption of
Natural Resources beyond permissible
limits
Major damage to
surrounding /
neighboring buildings

Legislation Legislation score indicates the compliance with the identified Legal and
Statutory Requirements applicable to the organization. This rating ranges from 1 to 2 as
below:
Compliance Description

Compliance Scale

Doesnt Comply with Legislation Requirements

Complies with Legislation requirements

Control Control score indicates the level of control to prevent the occurrence of the
environmental aspect. This rating ranges takes values of 1,3 and 9 as given below. Scale
of 1-3-9 is taken to bring out significant difference between very high control and
moderate control.
Control Description
Very High Control
Moderate Control
No Control

Control Scale
1
3
9

Detection Detection score indicates the likelihood of detecting the failure of process.
The rating for this parameter ranges between 1 to 5 as given below:
Detection Description

Detection
Scale

Almost Impossible It is very unlikely that failure would be


detected
Very Remote There is a chance failure would be detected in
a reasonable span of time

5.2.8

5
4

Moderate detection Failure would be detected after a


significant period of time

Immediate Failure would be detected almost immediately

Almost Certain - Current control(s) almost certain to detect


the failure mode. Reliable detection controls are know with
similar process

The team rates the product or activity based on the factors and a Risk Priority Number
(RPN) Value of Environmental Aspects and Impacts as a product of Quantity, Occurrence,
Impact, Legislation, Control and Detection.

5.3

Determining Significance

5.3.1

RPN Value shall be used for determining the significant environmental aspects and impacts
on which actions shall be implemented to reduce the environmental risks.

5.3.2

Threshold levels of RPN Values shall be periodically reviewed during the management
reviews to reduce the same based on the environmental performance achieved and
requirements of the applicable standards, legal, regulatory and other requirements, if any.

5.3.3

Environmental Aspects shall be prioritized for improvement action based on their


significance determined as given below:
Significant
RPN Value is greater than or
equal to 1000 (or) Legal
Compliance not being met
(Rating of2)
Impact is greater than or
equal to 6

Action
Initiate Environmental Management Program (EMP) to
reduce the risk and establish Operational Control
Procedures (OCP) to sustain the improvements
Establish Operational Control Procedures (OCP) to define
the controls to be exerted on the process to reduce the risk

5.4

Reporting the Assessment Results

5.4.1

The details of the assessment as described above are recorded in Environmental Aspect and
Impact Assessment Report of the respective product/ activity.

5.4.2

If the Core Team determines that additional information is needed to evaluate a particular
product or activity, the Plant Head assigns the responsibility for collecting that information
to appropriate personnel. Once the information is made available, then EMS Core Team
shall continue with the aspect and impact assessment.

5.4.3

EHS Manager is responsible for working with EMS Core Team to ensure that significant
environmental aspects identified by the team are considered in setting environmental
objectives and targets for the respective sections or departments.

5.4.4

Respective HODs shall initiate Environmental Management Programs (EMP) to reduce the
environmental risks of the significant aspects in their respective areas as described in
Procedure for Environmental Management Programs.

5.5

Follow-up Evaluation:

5.6

Follow-up evaluations or periodical evaluations are carried out once in a year or as decided
in the management reviews. The results of the most recent environmental aspect/ impact
identification are reviewed during the Management Reviews. Based on this review, the
EMS Core Team determines the need to update the environmental aspect and impact

evaluation. Factors such as improved assessment methodologies, or major changes to the


organizations mission, products and processes are considered in determining the need to
update the assessment.
5.7

Need arising out changes in Legal Requirements:

5.7.1

Whenever changes in legal requirements arise, EHS Manager shall review the same against
the most recent aspect and impact evaluation results. The results are reviewed with the MR,
EMS Core Team and Plant Head and the required changes in rating of the impacts are
incorporated.

5.7.2

Then the process described above is followed in case of significant aspects and impacts.

5.8

Need arising due to changes in products, process or activities:

5.8.1

Whenever changes are required to be made in the products or process, concerned HOD
initiates the same using Manufacturing Information Change raised on HOD Process
Development. HOD Process development and EHS Manager in turn review the aspects
and impacts of the changes and records the same on MIC.

5.8.2

MD along with Plant Head reviews the impact of changes on environment and decides
whether to approve the change or not. In case the change is not approved, MIC is returned
to the initiator. In case the change is acceptable, then approved MIC is sent to respective
HODs for initiating the required actions.

5.9

Respective HOD with assistance from EHS Manager then modifies the concerned Aspect
and Impact Assessment Reports. In case the changes result in possibility of any significant
environmental impacts, the same are handled as described above.

6.0

ABBREVIATIONS

6.1

IQEMS Integrated Quality and Environmental Management System

6.2

EMSCTM EMS Core Team Member

6.3

Environmental Aspect The elements of an organization's activities, products and


services that can interact with the environment are called environmental aspects. Examples
include a discharge, an emission, consumption or reuse of a material, or generation of noise.

6.4

Environmental Impact - Changes to the environment, either adverse or beneficial,


that result wholly or partially from environmental aspects are called environmental impacts.
Examples of adverse impacts include pollution of air, and depletion of natural resources.
Examples of beneficial impacts include improved water or soil quality.

7.0

8.0

REFERENCES

7.1

MSDS of Respective Materials

7.2

Legal and Regulatory Requirements identified in Legal Compliance Register

ANNEXURE
8.1

Environmental Aspect and Impact Assessment Report (Annexure 1 and Doc No: F01-00-NES011)

9.0

SUMMARY OF CHANGES
Version

Change Control

No.

No.

Reason for revision

END OF DOCUMENT

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