HEALTH & SAFETY MANUAL

Document Level – I



HSM : 00
Revision : 00
Issue: A

EFFECTIVE DATE : 05.11.2004

Designation of Holder : Management Representative

Total Pages : 44

Controlled / Uncontrolled Copy : Controlled copy

Safety Management System – OHSAS 18001:1999


RUSHIL INDUSTRIES LTD.
Plot no. 54, Ship Breaking Yard, Alang
P.O. Manar- 364150 (Gujarat.)
! !! ! (02842)-235466/ 235506 FAX: (0278)-2515676
E-mail: rl@wilnetonline.net

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Health and Safety Manual
[Clause no. 4.4.5 OHSAS 18001:1999]


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FM-MGT-04 HSM-Document Control Record
Clause No.


0.1 Title : HEALTH AND SAFETY MANAGEMENT MANUAL

0.2 Document no. : HSM-00 OHSAS 18001:1999

0.3 Issue to :

Copy no. Name of the copy holder Designation Department
01 Management Representative
Environment &
Safety Supervisor
Environment &
Safety

0.4 Revision Record


Date of
Revision
Revision
no & page

Revision Details

Approved by /
date


















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HSM - 00 Table of Contents


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Description of Clauses – OHSAS 18001:1999 HSM OHSAS
Clause No.
Pages
Cover page --- 1
HSMM- Document Control Record --- 2
Table of contents --- 3
Letter of Authorization --- 4
Scope of our Health & Safety management system --- 5-9
Organization Fact sheet --- 10-12
Regulatory Approvals --- 13
Organization chart --- 14
Responsibility & Authority --- 15,16
Scope 1 17
Reference publications 2 18
Terms and definitions 3 19-21
OH&S management system elements 4 22
General requirements 4.1 22-23
OH&S policy 4.2 24,25
Planning 4.3 26-30
− Planning for hazard identification, risk assessment and risk control 4.3.1 26-27
− Legal and other requirements 4.3.2 28
− Objectives 4.3.3 29
− OH&S management programme(s) 4.3.4 30
Implementation and operation 4.4 31-38
− Structure and responsibility 4.4.1 31
− Training, awareness and competence 4.4.2 32
− Consultation and communication 4.4.3 33-34
− Documentation 4.4.4 35-36
− Document and data control 4.4.5 36
− Operational control 4.4.6 37
− Emergency preparedness and response 4.4.7 38
Checking and corrective action 4.5 39-43
− Performance measurement and monitoring 4.5.1 39-40
− Accidents, incidents, non-conformances and corrective and preventive
action
4.5.2 41
− Records and record management 4.5.3 42
− Audit 4.5.4 43
Management review 4.6 44
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EM-00 Letter of Authorization




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This evidence of authorization for approval of the contents of the Health and Safety
Management Manual by Director is as follows:

I myself have studied, reviewed & finally approved contents of this Health and safety manual which
is prepared for meeting all requirements of OHSAS 18001:1999 in tandem with legal and other
requirements, which is implemented & continually improved in RUSHIL INDUSTRIES LTD., Alang,
Dist: Bhavnagar










Place: Alang, Dist:Bhavnagar
Date: 05.11.04 Director





[This manual may only be reproduced with written permission from Management Representative]
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INTRODUCTION
The Director of M/s RUSHIL INDUSTRIES LTD. has taken a strategic decision to adopt OHSAS
18001: 1999 Health & Safety Management System in the organization. The design and
implementation of our Health & Safety management system is influenced by application of
relevant and specific International Standards i.e OHSAS 18001 :1999, statutory and regulatory
guidelines by GMB and other legal requirements, particular objectives of the processes
employed and the size and structure of our organization.

This Health & Safety Management Manual may be used for reference by internal and external
parties, including certification bodies, to assess the organization’s ability to meet legal, regulatory
& organization’s own requirements.

Scope of our Health & Safety management system includes “ Breaking of ships, sale of steel
and other materials, components, machinery derived from ships.”

APPLICABLE CLAUSES OF HEALTH & SAFETY MANAGEMENT SYSTEM:

As described in Clause 1 i.e. Scope of the Standard, All the requirements of this standard are
incorporated in this Health & Safety management system, Our organization has established
documented, implemented and maintained an amalgamated Health & Safety management
system and continually improves its effectiveness in accordance with the requirements of relevant
and specific legal requirements and International standards as referred in Introduction above.

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COMPREHENSION OF OUR HEALTH & SAFETY POLICY:

The Director with involvement of the MR and Plot Manager has prepared the Health & Safety
Policy and Health & Safety Objectives for the organization. The Health & Safety Policy and Health
& Safety Objectives are developed while keeping in mind the ultimate goal of meeting legal and
other requirements and growth of the organization with favorable Health & Safety risks.


OUR HEALTH & SAFETY MANUAL

This Health & Safety manual is prepared after studying, discussing and analyzing all the Health
& Safety aspects, significant risks on Health & Safety with current working and planning future
business requirements. It contains (a) general and specific information about the organization and
(b) requirements of OHSAS 18001 :1999 Health & Safety Management System. The detailed
explanation is as under

PURPOSE:

This Health & Safety Manual is established and documented for the purpose including, but not
limited to the following:

a) Describing and implementing an effective Health & Safety management system
b) Communicating the organization’s Health & Safety policy, procedures, processes and
requirements
c) Providing improved control of Health & Safety risks and ensuring that they are under
periodic review.
d) Providing documented base for auditing the Health & Safety system
e) Providing continuity of the Health & Safety management system and its requirements
during changing circumstances
f) Training personnel in the Health & Safety management system requirements and
methods of compliance
g) Presenting the Health & Safety management system for external purposes, such as
demonstrating compatibility and integration with other management systems like OHSAS
18001 : 1999 .
h) Demonstrating compliance of the Health & Safety management system with Health &
Safety requirements in contractual situations.

STRUCTURE & FORMAT

It conveys accurately, completely and concisely the Health & Safety policy, quantified objectives
with targets for accomplishments and governing documentation processes and procedures of the
organization.

We have adapted a method of applying a key to various sections of this Health & Safety manual
and the Health & Safety elements of the governing Health & Safety management system
standard for assuring that the subject matter is adequately addressed and located.




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CONTENTS

This Health & Safety Manual consists of, or refers to, the documented Health & Safety
management system procedures and processes intended for overall planning and administration
of activities that have impact on Health & Safety within our organization.

This Health & Safety Manual covers all the applicable elements of Health & Safety management
system standard i.e. OHSAS 18001 :1999. It describes to the degree of detail required for
adequate control of the activities concerned, the responsibilities, authorities and interrelationships
of the personnel. These are the personnel who manage, perform, verify or review (a) work
affecting Health & Safety (b) how the different activities are to be performed (c) the documents to
be used and (d) the controls to be applied.

FINAL REVIEW AND APPROVAL:

Prior to issuing the manual, the document was reviewed by responsible individuals to ensure
clarity, accuracy, suitability and proper structure. The intended users also had the opportunity to
assess and comment on the usability of the document.

The Director who is responsible for implementation has approved this Health & Safety manual
and then released. Each copy bears evidence of this release authorization.




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DISTRIBUTION OF THE MANUAL :

The method of distribution of the authorized manual, whether in total or by sections, provides
assurance that all users have access.

Proper distribution and control is being aided, for example, by serialization of copies of recipients.

Our top management has ensured that individuals are familiar with those contents of the manual
appropriate to each user within the organization.

MANOEUVRABILITY:

a) Health & Safety Manual is revised whenever changes are made in the stipulated policies
and is regularly maintained by MR. The Director & MR carry out the review of the
manually. However, the MR is authorized to make changes in the contents of the HSM
with the approval of the Director.

b) Following officer is officially identified to assist MR and discharge the required
responsibilities in absence of MR.

[1] Mr. Nirav D. Motiwala (Plot Manager)

c) In case of special circumstances, like absence of Environment and Safety Supervisor,
the employee can directly approach Plot Manager with a justification for the changes to
be made.

d) In case of absenteeism at any level, the responsibility goes downward & authority
upward.
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INCORPORATION OF CHANGES:

A method of providing for the initiation, development, review, control and incorporation of
changes to the manual is provided.

This task is assigned to an appropriate document control function, which is handled by MR. The
same review and approval process used in developing the basic manual is being applied when
processing the changes.

Issue and change control:

Document issue and change controls are established to ensure that the content of the manual is
properly authorized.

" The authorized content is readily identifiable. Various methods are considered for
facilitating the physical process of making changes.
" To ensure that each manual is kept up to date, a method is determined to assure that all
changes are received by each manual holder and incorporated in to copy of each
manual. A separate revision-status page is used to assure the users that they have the
authorized manual/copy of procedures.


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HSM-00 ORGANIZATION FACT SHEET





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Organization : RUSHIL INDUSTRIES LTD.

Established in :

Nature of ownership :

Director : Mr. Ketan S. Seth

Plot Manager : Mr. Nirav D. Motiwala

Environment and safety : Mr. Pravin H. Jani
Supervisor

OHS Representative : Mr. Kabir M. Yadav

Total handled DWT till now :

Total ships broken till now :

Major fire occurrences :

Occurred during :

Fatal casualties till now :

Occurred during :

Infrastructure

Plot area :

Wastage storage space :

Water tank capacity :

Number of gas meters & oxygen :
meters

Other resource details :--

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SET- UP OF THE ORGANIZATION

• Organization hierarchy

The organization is led by Director , ________________ having more than 20 years of
experience in the industry .The introductory details like name, experience & designation of key
members are as under :


Sr.
No.
Name

Qualification /
Experience Designation

1 Mr. Ketan S. Seth Director
2 Mr. Nirav D. Motiwala Plot Manager
3 Mr. Pravin H. Jani ESS
4 Mr. Kabir M. Yadav OHS Representative

List of Resources available :

Steel cutting guns :

Gas pipe in meters :

Cranes :

Winch :

LPG cylinders :

Oxygen cylinders :

Environment and safety equipment

Wastage storage space :

Buckets for waste collection :

Fire extinguishers :

CO2 Foam :

CO2 Powder :

Fire fighting suits :

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Oxygen masks :

Sand buckets :

Limit of insurance taken :

Fire fighting pumps :

Helmets :

Anti-glare glasses :

Safety belts :

Mask for steel cutting :

Aprons / Boiler suits for steel cutting :

Hand gloves :

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HSM - 00 REGULATORY APPROVALS

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# List of regulatory authorities :

1. Gujarat Maritime Board Alang Gujarat
2. Department of Explosives Baroda Gujarat
3. Gujarat Pollution Control Board Baroda Gujarat
4. Department of Indian Customs Alang Gujarat
5. Ministry of Health & Safety & Forest New Delhi
6. Factories Inspectorate Alang Gujarat

Letter of approvals received from regulatory authorities :

Srno. Title of letter / certificate Ref no. Date
01 License to operate from
GMB

02 Health certificate File
03 GPCB hazardous storage
authorization.

04 LPG Storage License


Please refer LS-MGT-03 for applicable legal legislations and regulations
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Our organization follows a lean hierarchy in the following manner.






















Director
Plot Manager
Environment and Safety Supervisor
(Management Representative)
Field Supervisor
Ship Supervisor Crane and Winch
Operators
Gas cutters & helpers
Gas cutters & helpers
Workshop In-charge
Organization structure
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RESPONSIBILITY & AUTHORITY:

Persons familiar with good environment practices, procedures, objectives and assessment of the
results, provide supervision.

The responsibility, authority and the inter-relation of personnel who manage, perform and verify
work having significant environment impacts is defined and documented, particularly for
personnel who need the organizational freedom and authority to;

a) Initiate action to prevent the occurrence of any nonconformities relating to the
environment , process and environment management system.
b) Identify and record any problems relating to the , process and Health & Safety
management system.
c) Initiate, recommend or provide solutions through designated channels.
d) Verify the implementation of preventive and corrective actions
e) Control further continuation of nonconforming activity until the deficiency or unsatisfactory
condition has been corrected.

We hereby declare and ensure that our management and personnel are free from any undue
internal and external commercial, financial and other pressures and influences that may
adversely affect the Health & Safety of their work.

Sr.
No.
Responsibility Authority Interfacing with
01 Director
- Introduction review and continual
improvement of modern Health &
Safety management system
OHSAS 18001 :1999 and overall
Health & Safety management
- Marketing Function, Resources
management
- Encourage training for all
employees
- Decision on Health & Safety risk
rating and its review, Health &
Safety Manual review
- Review of performance of
significant Health & Safety risks &
hazards
- Planning, Health & Safety
Management Program reporting
- Review of Legal requirements
- External communication
- Management Reviews
He enjoys full
freedom to take
independent
decisions in the
Health & Safety al
interests of
organization
Plot Manager

Environment & Safety
Supervisor

GMB

State and Central
government
authorities

GPCB

Dept of explosives

Customs department




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02 Plot Manager
- Dispatch management
- Plot management including steel
cutting, pumping out of oil, beaching,
crane and winch operations.
- Waste management planning
- Internal audits, Corrective and
preventive action
- Implementation of regulations from
Regulatory Authorities
- Ensure that operations are controlled
according to legal requirements
- Ensure that all documents are updated
timely, Health & Safety procedure
review
- Implement actions from management
review
- Achievement of Health & Safety
objectives
Enjoys full freedom
for discharging his
duties.

Implement policies
at plot as per
requirements and
practical situations

Meeting all
requirements of
legal & regulatory
authorities.
NEPL Site

Environment and
Safety Supervisor

Gas cutters and
helpers


03 Environment & Safety Supervisor (ESS)- (Management Representative)
- Ensure that all Health & Safety practices
are followed by steel cutters, helpers,
crane operators and winch operators
- Ensure that all non-confirming activities
are identified
- Ensure that all corrective & preventive
actions decided are implemented
- Request for all resources to Plot
Manager
- Reporting of any abnormal situations if
occurred
- Health & Safety control during steel
cutting, crane operations, waste
handling, wastage storage space,
- Achievement of Health & Safety
objectives
- Review and practice of Emergency
preparedness
- Ensure that OHSMS is established,
implemented and maintained in accordance
with OHSAS 18001.
- Report the performance of OHSMS to
director and Plot manager for review &
details of improvement carried out in OHSMS
- Enjoys full
freedom to
take decisions
on
implementing
methodologies
of ship
breaking ,
material
handling on
ship and on
plot.
Plot Manager
Director
Gas cutter
Helpers
Responsibilities, authorities and other activities of rest of employees are defined in
Good Safety Practices- Document Level III



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1. SCOPE

This Occupational Health and Safety manual gives requirements for an
occupational health and safety (OH&S) management system, to enable our
organization to control our OH&S risks and improve our performance.

This OHSAS manual is applicable to our organization as we wish to:

a) Establish an OH&S management system to eliminate or minimize risk to
employees and other Interested parties who may be exposed to OH&S risks
associated with our activities;
b) Implement, maintain and continually improve our OH&S management system;
c) Assure itself of our conformance with our stated OH&S policy;
d) Demonstrate such conformance to others;
e) Seek certification/registration of its OH&S management system by an external
organization; or
f) Make a self-determination and declaration of conformance with this Health and
Safety Manual.

All the requirements in this manual are intended to be incorporated into our
OH&S management system. This OH & S manual is intended to address
occupational health and safety rather than product and services safety sold by
us.

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2. REFERENCE PUBLICATIONS

OHSAS 18001 :1999 , Occupational Health and Safety Assessment Series .
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HSM-00 TERMS AND DEFINITIONS





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3. TERMS AND DEFINITIONS
For the purposes of this OHSAS specification the following terms and definitions
apply.

3.1 accident
undesired event giving rise to death, ill health, injury, damage or other loss that
may occur at our premises.

3.2 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 our organization's OH & S
policy and objectives

3.3 continual improvement
process of enhancing the OH&S management system, to achieve improvements
in overall occupational health and safety performances, in line with our
organization's OH&S policy.

3.4 hazard
source or situation with a potential for harm in terms of injury or ill health,
damage to property, damage to the workplace Health & Safety, or a combination
of these that may occur at our premises.

3.5 hazard identification
process of recognizing that a hazard exists and defining its characteristics

3.6 incident
event that gave rise to an accident or had the potential to lead to an accident at
our premises.

3.7 interested parties
individual or group concerned with or affected by the OH&S performance of an
organization

3.8 non-conformance
any deviation from work standards, practices, procedures, regulations,
management system performance etc. that could either directly or indirectly lead
to injury or illness, property damage, damage to our workplace Health & Safety,
or a combination of these

3.9 objectives
goals, in terms of OH&S performance, that our organization sees itself to
achieve
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3.10 occupational health and safety
Conditions and factors that affect the well-being of our employees, temporary
workers, contractor personnel, visitors and any other person in the workplace

3.11 OH&S management system
part of our overall management system that facilitates the management of the
OH&S risks associated with the business of our organization. This includes the
organizational structure, planning activities, responsibilities, practices,
procedures, processes and resources for developing, implementing, achieving,
reviewing, and maintaining our organization's OH&S policy

3.12 organization
RUSHIL INDUSTRIES LTD. Is a closely held Limited company.

3.13 performance
measurable results of the OH&S management system, related to our
organization's control of health and safety risks, based on our OH&S policy and
objectives


3.14 risk
combination of the likelihood and consequence(s) of a specified hazardous event
occurring

3.15 risk assessment
overall process of estimating the magnitude of risk and deciding whether or not
the risk is tolerable

3.16 safety
freedom from unacceptable risk of harm

3.17 tolerable risk
risk that has been reduced to a level that can be endured by our organization
having regard to our legal obligations and its own OH&S policy

3.18 Director
The director is one of the member of board of the organization.
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Abbreviations

Srno. Abbreviation Meaning
1 GSP Good Safety Practice
2 MR Management Representative
3 OH& SMS
Occupational Health & Safety Management
System
4 GMB Gujarat Maritime Board
5 ESS Environment and Safety Supervisor
6 SC Steel cutter
7 Pipe valve
(Ghadi) valve that is fitted to the pipe
connecting gas gun and cylinder
8 Cylinder LPG and Oxygen cylinder
9 GPCB Gujarat Pollution Control Board
10 SMP Safety Management Program
11 I & O Implementation and Operation
12 C & CA Checking and corrective action
13 CAPA Corrective and preventive action
14 OH & S Occupational Health and Safety

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General Requirements
HSM-00
Clause no.4.1 – OHSAS 18001 :1999




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4. OH&S MANAGEMENT SYSTEM ELEMENTS
4.1 General requirements
4.1.1 POLICY:

The organization (top management) has established, documented, implemented
& maintained an OH & S Management System and continually improve its
effectiveness in accordance with the requirements of OHSAS 18001 :1999 as a
means of ensuring that our activities confirm to specified requirements.

4.1.2 SCOPE :

This policy is applicable to ship breaking, handling, storage and sale of products
and by-products derived from the ship.

4.1.3 RESPONSIBILITY

The Management Representative [MR] is totally responsible for implementation
of this policy and achieving the purpose.

4.1.4 PROCEDURE

To implement the OH & S Management System top management have
collectively worked and prepared the complete Health & Safety manual & have
prepared and documented procedures and good safety practices while keeping
focus on our OH & S policy.

The requirements of our OH & S management system are described in the
following manual which include :

1. Health and Safety policy
2. Planning
a. Hazard identification, risk assessment and risk control
b. Legal and other requirements
c. Objectives
d. OH & S management programme
3. Implementation and Operation
a. Structure and Responsibility
b. Training, awareness and competence
c. Consultation & Communication
d. Documentation
e. Document and data control
f. Operational control
g. Emergency preparedness and response
4. Checking and corrective action
a. Performance measurement & monitoring
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General Requirements
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Clause no.4.1 – OHSAS 18001 :1999




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b. Accidents, incidents, Non-conformance and corrective and
preventive action
c. Records & records management
d. Audit
5. Management Review

4.1.5 Records
NIL
4.1.6 Reference Documents
NIL
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Health & Safety Policy
HSM-00
Clause no.4.2 – OHSAS 18001 :1999




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4.2 OH & S policy

4.2.1 POLICY

The top management with executive responsibility has defined and documented Health
& Safety policy for our organization and its commitment to risk control .

4.2.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship.

4.2.3 RESPONSIBILITY

The Health & Safety policy is well communicated to and understood by all employees
and accepted as a prime responsibility to comply with hence bear their whole hearted
support.

4.2.4 PROCEDURE

In establishing our organization’s Health & Safety policy , top management has ensured
that

a) Is appropriate to the nature, scale and OH & S risks of our ship breaking activities.;

b) Includes a commitment to continual improvement and minimization of risks;

c) Includes a commitment to comply with relevant OH & S legislation and regulations
as described in list of applicable legislations and regulations.

d) Is documented, implemented and maintained and communicated to all employees;

e) Is communicated to all employees with the intent that employees are made aware of
their individual OH & S obligations.

f) Is available to interested parties and

g) Is reviewed periodically to ensure that it remains relevant and appropriate to the
organization.

Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
Health & Safety Policy
HSM-00
Clause no.4.2 – OHSAS 18001 :1999




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After reviewing the above considerations, Environmental and Safety policy of our
organization is as follows :

We at RUSHIL INDUSTRIES LTD. which is a ship breaking unit are committed to continual
improvement of our occupational health & safety and environment control processes
aimed at prevention of all types of pollution and minimization of occupational health and
safety risks. We shall strive to achieve this by :

1. Complying with applicable occupational health, safety and environment
legislations
2. Striving to achieve the occupational health, safety and environment objectives and
targets
3. Communicating this policy to all employees and make it available to interested
parties and public.

This policy shall be reviewed regularly.
=============x================x==============x===============
pyRavr` AOr Vyvsaihk sur9a poilsI

ruxIl {NDiS3/s ilim3eD (RUSHIL INDUSTRIES LTD.) me. kam krne vale swI log pyaRvr` AOr
Vyvsaiyk sur9a ke inr.tr su2ar ke il0 yh p/` krte hE., ik

− hm sb imlkr pyaRvr` AOr kmRcairyo. kI Vyvsaiyk sur9a ka pUra @yan rqe.ge|
− hm pr lagU pyaRvr` AOr Vyvsaiyk sur9a ke sare kanUno. ka pUra paln kre.ge|
− pyaRvr` AOr Vyvsaiyk sur9a ke iniXct ]deXy AOr @yey ko haisl krne kI pUrI koixx kre..ge|
− Apne kmRcarI , ga/hk AOr sPlayr ko ApnI pyaRvr` AOr Vyvsaihk sur9a inityo.. kI jankarI
dete rhe.ge|

yh poilsI kI jankarI hmare swI 63ko. ko smy smy pr 3/ein.g AOr AapsI smvad se dete rhege |


Reference documents

HSM -00 Health & Safety Manual

Records

NIL
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
Planning of hazard identification, risk assessment and
risk control
HSM-00
Clause no.4.3.1 – OHSAS 18001 :1999




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4.3 PLANNING

4.3.1 Hazard identification, risk assessment and risk control

4.3.1.1 POLICY :

The top management of the organization has identified, assessed and controlled
occupational risks of our ship breaking activity.

4.3.1.2 SCOPE :

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.3.1.3 RESPONSIBILITY
The Director is responsible for implementation of this policy and achieving the purpose.

4.3.1.4 PROCEDURE

The Director of the organization has identified, assessed and controlled occupational
risks of ship breaking activity that we can control and over which we can be expected to
have an influence as described in List of health and safety hazards [LS-MGT-01] , in
order to determine those which have or can have unacceptable risk as described in List
of hazards to be controlled [LS-MGT-02] .

In the above process we have ensured that the hazards related to unacceptable risks
are considered in setting our Health & Safety objectives as described in [FM-MGT-01]
which is updated every 6 months.

Entire details of the this activity is given in HSP – 02 Procedure for Identification of
health and safety hazards
The hazards identified include :
• Routine and non-routine activities
• Activities of all personnel having access to plot (including suppliers and visitors)
• Facilities at the plot which are all provided by the organization.
The organization has ensured that the results of these assessment and effects of
these controls are considered when setting our OH&S objectives. Our
organization has documented and keeps this information up to date.

Our organization's methodology for hazard identification and risk assessment is
been defined with respect to our scope, nature and timing to ensure it is
proactive rather than reactive;

Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
Planning of hazard identification, risk assessment and
risk control
HSM-00
Clause no.4.3.1 – OHSAS 18001 :1999




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• It provides the classification of hazards and identification of those that
are to be controlled by measures as defined in List of hazards to be
controlled [LS-MGT-02]
• Is consistent with operating experience and the capabilities of hazard
control measures employed;
• It provides input into the determination of facility requirements,
identification of training needs and/or development of operational
controls;
It provides information for monitoring of required actions to ensure both the effectiveness
and timeliness of their implementation.

Reference Documents
LS-MGT-01 List of health and safety hazards
LS-MGT-02 List of hazards to be controlled
FM-MGT-01 Health & Safety objectives
HSP – 02 Procedure for Identification of health and safety hazards

Records
NIL
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
Planning-Legal and other requirements
HSM-00
Clause no.4.3.2 – OHSAS 18001 :1999




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4.3.2 Legal and other requirements

4.3.2.1 POLICY :

The Top management has identified and has access to legal and other requirements to
which our organization subscribes.

4.3.2.2 SCOPE :

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.3.2.3 RESPONSIBILITY

The Director is responsible for implementation of this policy and achieving the purpose.

4.3.2.4 PROCEDURE

The Director of the organization has identified, established and maintained legal and
other requirements to which the organization subscribes, that are applicable to health
and safety hazards [LS-MGT-01] of our ship breaking activity. The applicable legal
requirements are described in List of applicable legal legislations as described in [LS-
MGT-03] Entire details of the this activity is given in HSP- 01 Procedure for identification
of legal and other requirements. Our organization updates legal requirements whenever
there is a change occurring due to industry, state or national level legislations which are
recorded in Legal Requirement updation form [SR-MGT-16]



Reference Documents
LS-MGT-01 List of health and safety hazards
LS-MGT-02 List of hazards to be controlled
LS-MGT-03 List of applicable legal legislations
HSP-01 Procedure for identification of legal and other
requirements.
Records
SR-MGT-16 Legal Requirement up-dation form
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
Planning- Objectives
HSM-00
Clause no.4.3.3 – OHSAS 18001 :1999




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4.3.3 OBJECTIVES

4.3.3.1 POLICY

The organization has established, maintained and documented Health & Safety
objectives, at each relevant function and level within the organization

4.3.3.2 SCOPE :

This policy is applicable to List of hazards to be controlled [LS-MGT-02] , its
technological options and its financial, operational and business requirements and the
views of interested parties.
.

4.3.3.3 RESPONSIBILITY

All Health & Safety objectives are well communicated to and understood by all
employees and accepted as a prime responsibility to achieve the same to comply with
OH & SMS.

4.3.3.4 PROCEDURE

When establishing and reviewing our objectives as described in [FM-MGT-01], we have
considered the legal and other requirements, its OH & S hazards and risks, its
technological options and its financial, operational and business requirements, and the
views of interested parties.

The objectives have been consistent with the Health & Safety policy, including the
commitment to continual improvement.

Reference documents
LS-MGT-02 List of hazards to be controlled
FM-MGT-01 Health & Safety objectives

Records
NIL
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
Planning - OH & S management programme
HSM-00
Clause no.4.3.4 – OHSAS 18001 :1999




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4.3.4 OH & S management programme

4.3.4.1 POLICY :

The top management has established and maintained OH & S management programme
for achieving our Health & Safety objectives [FM-MGT-01]

4.3.4.2 SCOPE :

This policy is applicable to List of hazards to be controlled [LS-MGT-02] , its
technological options and its financial, operational and business requirements and the
views of interested parties.

4.3.4.3 RESPONSIBILITY

The OH & S management programme is well communicated to and understood by all
employees and accepted as a prime responsibility to achieve the same to comply with
OH & SMS

4.3.4.4 PROCEDURE

The OH & S management programme include

a) Designation of responsibility for achieving objectives at each relevant function and
level of the organisation;

b) The means and time-frame by which they are to be achieved.

c) The OH & S management programme is reviewed every 6 months. Whenever felt
necessary it is amended to address changes to our ship breaking activities &
operating conditions of our organization.

Details of above activities can be found in OH & S Management Programme [FM-MGT-
02]

Reference documents
FM-MGT-02 OH & S Management Programme
LS-MGT-02 List of hazards to be controlled
FM-MGT-01 Health & Safety objectives

Records
NIL
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O- Structure and Responsibility
HSM-00
Clause no.4.4.1 – OHSAS 18001 :1999




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4.4 Implementation and operation

4.4.1 Structure and Responsibility

4.4.1.1 POLICY :

The Top management has defined, documented and communicated roles, responsibility
and authorities in order to facilitate effective OH & S management.

4.4.1.2 SCOPE :

This policy is applicable to all the employees of the organization.

4.4.1.3 RESPONSIBILITY

This policy is responsibility to all concerned employees of the organization.

4.4.1.4 PROCEDURE

Top Management has provided resources essential to the implementation and control of
the OH & S management system. Resources include human resources and specialized
skills, technology and financial resources.

The organisation’s top management has appointed (a) specific management
representative who, irrespective of other responsibilities, have been defined roles,
responsibilities and authority for

a) Ensuring that OH & S management system requirements are established,
implemented and maintained in accordance with OHSAS specifications.

b) Reporting on the performance of OH & S management system to top management
for review and as a basis for improvement of OH & S management system.

However the ultimate responsibility for occupational health and safety rests with top
management. All those with management responsibility demonstrate their
commitment to the continual improvement of OH&S performance by practically
implementing the same and improving to changing circumstances of legal and
business environment.

Reference documents
HSM-00 Pg 15-17 Health & Safety Manual

Records
NIL
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O- Training, awareness & competence
HSM-00
Clause no.4.4.2 – OHSAS 18001 :1999




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4.4.2 Training, awareness and competence

4.4.2.1 POLICY

The top management has a system to identify training needs. All personnel whose work
may create a significant impact upon the environment, are provided with appropriate
training.

4.4.2.2 SCOPE

The policy is applicable to all employees working in the organization.

4.4.2.3 RESPONSIBILITY

Plot Manager is responsible to implement this policy in the organization and achieve the
purpose

4.4.2.4 PROCEDURE

The Plot Manager has ensured that all employees or members at each relevant function
and level are aware of

a) the importance of conformance with the OH & S policy and procedures and with the
requirements of the OH& S management system;

b) Hazards to be controlled , actual or potential, of their work activities and the OH & S
benefits of improved personal performance;

c) their roles and responsibilities in achieving conformance to the OH & S policy and
procedures and with the requirements of the OH & S management system, including
emergency preparedness and response requirements;

d) the potential consequences of departure from specified operating procedures.

Personnel performing the tasks, which can cause impact on OH & SMS , are competent
on the basis of appropriate education, training and/or experience as described in
organization skill chart [FM-MGT-03] . All the training needs identified and provided are
recorded in Identification cum training form [SR-MGT-02] Entire details of the this activity
is given in HSP- 04 Procedure for training awareness and competence.

Reference documents
FM-MGT-03 Organization skill chart
HSP-04 Procedure for training awareness and competence

Records
SR-MGT-02 Identification cum training need form
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O –Consultation and Communication
HSM-00
Clause no.4.4.3 – OHSAS 18001 :1999




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4.4.3 Consultation and Communication

4.4.3.1 POLICY

The top management had implemented system for communication to and from
employees and other interested parties with regard to our hazards to be controlled and
OH & S management system.

4.4.3.2 SCOPE

The policy is applicable to all Health & Safety hazards as described in List of Health &
Safety hazards in [LS-MGT-01]

4.4.3.3 RESPONSIBILITY

Director and Plot Manager are responsible to implement this policy in the organization
and achieve the purpose

4.4.3.4 PROCEDURE

The top management shall ensure that

• Communication and consultation from/ to/ between the various levels and functions
of our organization and other interested parties is carried out with regards to Health
& Safety hazards of the organization.

• The organization is receiving, documenting and responding to relevant
communication from employees which are recorded in Environment and safety
improvement form [FM-MGT-08]

• Relevant employees are involved in development and review of policies and
procedures to manage Health & Safety risks.

• Employees are consulted where there are any changes that affect workplace health
and safety.

• They are represented on Health & Safety matters.

• Informed as who is their Management Representative


Entire details of the this activity is given in HSP- 05 Procedure for internal and external
communication.


Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O –Consultation and Communication
HSM-00
Clause no.4.4.3 – OHSAS 18001 :1999




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Reference documents
LS-MGT-02 List of hazards to be controlled
HSP-05 Procedure for internal and external communication

Records
SR-MGT-01 External communication register
FM-MGT-08 Environment and safety improvement form
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O – Documentation
EM-00
Clause no.4.4.4
0HSAS 18001 :1999




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4.4.4 DOCUMENTATION

4.4.4.1 POLICY

The top management has established and maintained information in paper form related
to entire OH & SMS

4.4.4.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.4.4.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible to implement this
policy in the organization and achieve the purpose

4.4.4.4 PROCEDURE

The documentation is divided in four levels i.e

Level I Health & Safety Manual

Level II Health & Safety Procedures

Level III Good safety practices

Level IV Health & Safety records and formats


The complete hierarchy of documentation maintained for OHSAS 18001 :1999 OH &
SMS can be found in Master list of documents [ML-MGT-01]


Reference documents
ML-MGT-01 Master list of documents


Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O – Data Control
HSM-00
Clause no. 4.4.5
0HSAS 18001 :1999




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4.4.5 DATA CONTROL

4.4.5.1 POLICY

The top management has established and maintained information in paper form related
to entire OH & SMS

4.4.5.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.4.5.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible to implement this
policy in the organization and achieve the purpose

4.4.5.4 PROCEDURE

The system for control of documents is designed in such a way that ;

a) It describes the core elements of the management system and their interaction
b) Provides direction to related documentation
c) They are located;
d) They are periodically reviewed, revised as necessary and approved for adequacy by
authorised personnel;
e) The current versions of relevant documents are available at all locations where
operations essential to the effective functioning of the OH & S management system
are performed;
f) Obsolete documents are promptly removed from all points of issue and points of
use, or otherwise assured against unintended use;
g) Any obsolete documents retained for legal and/or knowledge preservation purpose
are suitably identified.

Our documentation is legible, dated (with dates of revision) and readily identifiable,
maintained in an orderly manner and retained for at least 3 years.

Entire details of the this activity is given in HSP- 03 Procedure for document and data
control.

Reference documents
HSP-03 Procedure for document and data control

Records
SR-MGT-03 Details of obsolete documents
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O- Operational control
HSM-00
Clause no.4.4.6 – OHSAS 18001 :1999




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4.4.6 OPERATIONAL CONTROL

4.4.6.1 POLICY

The top management has identified the operations and activities that are associated with
hazards to be controlled [LS-MGT-02] in line with our policy & objectives.

4.4.6.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.4.6.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible to implement this
policy in the organization and achieve the purpose

4.4.6.4 PROCEDURE

We have planned the activities, including maintenance, in order to ensure that they are
carried out under specified conditions by

a) Establishing and maintaining documented procedures to cover situations where their
absence could lead to deviations form the Health & Safety policy and objectives.

b) Stipulating operating criteria in the procedures;

c) Establishing and maintaining procedures related to the identifiable hazards that
need to controlled of activities of our organisation and communicating relevant
procedures and requirements to suppliers and contractors.

d) Workplaces, process, installations, machinery and their adaptations to human
capabilities eliminate or reduce OH & S risk at their source.

Entire details of this activity are given in HSP- 07 Procedure for Monitoring,
measurement & control of operations. Weekly operations records are maintained in
Operations control sheet [SR-MGT-04] , Maintenance control sheet [SR-MGT-05] .

Reference documents
LS-MGT-02 List of significant environmental aspects and impacts
HSP-07 Procedure for monitoring, measurement and control of
operations

Records
SR-MGT-04 Operations control sheet
SR-MGT-05 Maintenance control sheet
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
I & O – Emergency preparedness and response
HSM-00
Clause no.4.4.7 – OHSAS18001 :1999




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4.4.7 EMERGENCY PREPAREDNESS AND RESPONSE

4.4.7.1 POLICY

The top management has established and maintained procedures to identify potential for
and respond to accidents and emergency situations, and for preventing and mitigating
the likely illness and injury that may be associated with them.

4.4.7.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.4.7.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible to implement this
policy in the organization and achieve the purpose

4.4.7.4 PROCEDURE

It is vital for the organization to define, review the emergency preparedness and
response plan to deal with any emergency.

For this we shall:
- Identify the potential for and response to incidents and emergency situations.
- Take action to put plan in place to prevent & mitigate any likely illness and injury
associated with the emergency situation.
- Periodically test such preparedness by conducting emergency drill
- Review the emergency preparedness and response plans, particularly after
occurrence of any incident or emergency situation or once in 6 months.

Details of the this activity is given in HSP- 08 Procedure for Identification and control of
emergency situations.

Reference documents
HSP-08 Procedure for identification and control of emergency
situations.

Records
SR-MGT-08 Emergency drill record
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
C & CA – Performance measurement and monitoring
HSM-00
Clause no.4.5.1 – OHSAS18001 :1999




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4.5 Checking and Corrective action
4.5.1 Performance measurement and monitoring

4.5.1.1 POLICY

The top management has established and maintained various procedures to monitor
and measure, on a regular basis, the key characteristics of its operations and activities
that can minimize the risks of hazards to be controlled.

4.5.1.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.5.1.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible to implement this
policy in the organization and achieve the purpose

4.5.1.4 PROCEDURE

The above activity include
• Qualitative and quantitative measures, appropriate to the needs of the
organization, which can be verified in Operations control sheet [SR-MGT-04] and
Maintenance control sheet [SR-MGT-05]
• Monitoring of the extent to which the organization’s OH & S objectives are met
[FM-MGT-01]
• Proactive measures of performance that monitor compliance with the OH & S
management programme, operational criteria and applicable legislation and
regulatory requirements which are verified in Environment and safety
improvement form [FM-MGT-08] and Legal Requirement updation form [SR-
MGT-16]
• Reactive measures of performance to monitor accidents, ill health, incidents
(including near-misses) and other historical evidence of deficient OH&S
performance which are recorded in Non-conformance cum corrective action form
[SR-MGT-09]
• Recording of data and results of monitoring and measurement sufficient to
facilitate subsequent corrective and preventive action analysis [SR-MGT-09]
• Monitoring equipment is calibrated and maintained and records of this process
are retained according to the organisation’s procedures which can be found in
Maintenance and calibration plan [SR-MGT-06] and Calibration control sheet
[SR-MGT-07].

Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
C & CA – Performance measurement and monitoring
HSM-00
Clause no.4.5.1 – OHSAS18001 :1999




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The Director evaluates compliance with relevant Health & Safety legislation and
regulations every 6 months or during any receipt of new legislation or external
communication [SR-MGT-16]

Entire details of the this activity is given in HSP- 07 Procedure for Monitoring,
measurement & control of operations.




Reference documents
HSP-07 Procedure for monitoring, measurement and control of
operations.
SR-MGT-06 Maintenance and calibration control plan
FM-MGT-01 OH & S Objectives

Records
SR-MGT-04 Operations control sheet
SR-MGT-05 Maintenance control sheet
SR-MGT-06 Maintenance and calibration plan
SR-MGT-07 Calibration control sheet
SR-MGT-16 Legal Requirement updation form
SR-MGT-09 Non-conformance cum corrective and preventive action
form
FM-MGT-08 Environment and safety improvement form
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
C & CA – Accidents, incidents, non-conformances and
corrective and preventive action
HSM-00
Clause no.4.5.2 – OHSAS18001 :1999




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4.5.2 Accidents, incidents, non-conformances and corrective and preventive
action

4.5.2.1 POLICY
The top management has defined responsibility and authority for handling and
investigating non-conformances(accidents, incidents & non-conformances) taking action
to mitigate any impacts caused and for initiating and completing corrective and
preventive action.

4.5.2.2 SCOPE
This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.5.2.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible to implement this
policy in the organization and achieve the purpose

4.5.2.4 PROCEDURE

The organization has established and maintained procedures for defining responsibility
and authority for handling investigation of non-conformances which also include
accidents and incidents by
• Taking any corrective or preventive actions taken to eliminate the causes of actual
and potential non-conformances are ensured that they are appropriate to the
magnitude of problems and commensurate with the Health & Safety hazard
encountered.
• Any corrective and preventive action taken is reviewed through the risk assessment
process prior to implementation.

The top management has implemented and recorded any changes in the documented
procedures resulting from corrective and preventive action which can be reviewed in SR-
MGT-14 Change in procedures.

The entire details of the above activity is described in details in HSP-09 Control of non-
conformances, corrective and preventive action

Reference documents
HSP-09 Procedure for Control of non-conformances,
corrective and preventive action

Records
SR-MGT-09 Non-conformance cum corrective and preventive action
form
SR-MGT-14 Change in procedures
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
C & CA – Records & records management
HSM-00
Clause no.4.5.3 – OHSAS 18001 :1999




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4.5.3 RECORDS AND RECORDS MANAGEMENT
4.5.3.1 POLICY

The top management has planned, established and maintained the identification,
maintenance and disposition of Health & Safety records as well as the results of audits
and reviews.

4.5.3.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.5.3.3 RESPONSIBILITY

Plot Manager and Environment and Safety Supervisor are responsible to implement this
policy in the organization and achieve the purpose

4.5.3.4 PROCEDURE

The top management has ensured that environmental records are legible, identifiable
and traceable to the activities involved. OH & S records are stored and maintained in
such a way that they are readily retrievable and protected against damage, deterioration
or loss. Their retention times has been established and recorded. Records are
maintained, as appropriate to the system and to the organisation, to demonstrate
conformance to the requirements of this OHSAS specifications. The entire details of the
above activity is described in details in HSP-06 Control of records. A list of all the
records to be maintained can be found in Master list of documents [ML-MGT-01]



Reference documents
HSP-06 Procedure for Control of records

Records
ML-MGT-01 Master list of documents
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
C & CA – OH & S Audit
HSM-00
Clause no.4.5.4 – OHSAS 18001 :1999




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Plot Manager
Released by


Plot Manager



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Director
Page 43 of 44
4.5.4 OH & S AUDIT

4.5.4.1 POLICY

The top management has planned for periodic environmental management system
audits to be carried out every 6 months.

4.5.4.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.5.4.3 RESPONSIBILITY

Director, Plot Manager and Environment and Safety Supervisor are responsible to
implement this policy in the organization and achieve the purpose

4.5.4.4 PROCEDURE

Environmental audits are conducted in order to

a) Determine whether or not the OH & S management system
1) Conforms to planned arrangements for OH & S management including the
requirements of the OHSAS specification and
2) Has been properly implemented and maintained; and
3) Is effective in meeting the organization’s Health & Safety policy and objectives.

b) Review the results of previous audits where applicable.
c) Provide information on the results of audits to management.


The organization’s audit plan[SR-MGT-11] including any schedule, is based on risks
assessments of the organization’s activity and the results of previous audits. In order to
be comprehensive, the audit procedures [HSP-03] have covered the audit scope,
frequency and methodologies, as well as the responsibilities and requirements for
conducting audits and reporting results. The results of internal audit can be found in
Internal audit report [SR-MGT-12] Whenever possible, audits are performed by
personnel independent of those having direct responsibilities and requirements for
conducting audits and reporting results.

Reference documents
HSP-03 Procedure for Control of Internal environment
audits

Records
SR-MGT-12 Internal audit report
Rev no.00 Dt 05.11.04
Issue no.A Dt 05.11.04
RUSHIL INDUSTRIES LTD.
C & CA – Management Review
HSM-00
Clause no.4.6 – OHSAS 18001 :1999




Prepared by


Plot Manager
Released by


Plot Manager



Doc. Status
Authorized by


Director
Page 44 of 44

4.6 MANAGEMENT REVIEW

4.6.1 POLICY

The organisation’s top management every 6 months, reviews the OH & S management
system, to ensure its conducting suitability, adequacy and effectiveness.

4.6.2 SCOPE

This policy is applicable to ship breaking, handling, storage and sale of products and by-
products derived from the ship

4.6.3 RESPONSIBILITY

Director and Plot Manager are responsible to implement this policy in the organization
and achieve the purpose

4.6.4 PROCEDURE

The management review process ensures the necessary information is collected to
allow management to carry out this evaluation. This review is documented in Records of
management review [SR-MGT-13]

The management review addresses the possible need for changes to policy, objectives
and other elements of the OH & S management system, in the light of environmental
management system audit results, changing circumstances and the commitment to
continual improvement.

Reference documents
NIL

Records
SR-MGT-13 Records of Management Review

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