Compliance Obligation Procedure

OBJECTIVE

To establish the process(es) needed to:

a)Identify compliance obligations related to the needs / expectations of relevant interested parties, relevant environmental aspects and OHS requirements. 

b)Maintain knowledge, access and keep up to date legal and other EHS requirements to fulfil compliance obligations.

c)Evaluate fulfilment of compliance obligations.

SCOPE

Applies to the organisation’s activities, processes, products and services

RESPONSIBILITY

GM

The GM shall ensure resources are provided to access and obtain/purchase all relevant legal and other requirements from relevant agencies, Printers, etc.

Managers, Supervisors

Keep themselves updated on legal and other requirements applicable to their department’s activities, products and/or services. 

Determine how new or changes to legal and other requirements could impact the organization’s compliance obligations.

commit to develop action plans to ensure the organisation’s compliance from new requirements, change in existing requirements, compliance evaluation or audit findings, etc

EHS Officer

Maintain knowledge, access and identify legal and other EHS requirements relevant to the organisation.  This can be in the form of legal register, legal subscription services, etc.

Plan and perform compliance evaluation at least once a year

Share new requirements and/or results from compliance evaluation to the GM and Managers and advice on action that needs to be taken (if necessary) in order to fulfill the organisation’s compliance obligations.

DEFINITION

EHS – Environmental, Health and Safety

OHS – Occupational Health and Safety

PROCEDURE

1)The GM, Managers and the EHS Officer shall participate in the mapping of external and internal interested parties’ expectations and needs that are relevant to the QEHS Management system; and

2)Identify which of these expectations and needs become the organisation’s compliance obligations.

3)The output shall be maintained as documented information and used as a reference when planning the organisation’s QEHS objectives.

4)EHS Officer shall use this output above to develop and maintain appropriate Legal Registers (Appendix A, B, C, D ,E).  These registers are the organisation’s access to knowledge which  contributes to its ability to fulfil its compliance obligations and include:

Legislation related to Workplace Safety and Health;

Legislation related to Environmental Protection;

Legislation related to Fire Safety;

Applicable Codes of Practices;

Applicable organization’s Group’s Policies (e.g., esponsible Care Rules, etc);

•Non-regulatory Guidelines, etc

5)He / She shall update the Legal Register periodically, at least on a yearly basis.

6)Where there are new or impending changes which would impact the organisation’s ability to fulfil its compliance obligations, the EHS Officer shall report to the GM and all relevant Managers and provide advice (if necessary) on action to be taken. 

7)The respective Managers  shall regularly keep track of changes to legal and other requirements via various media and approaches, e.g. 

•Monitoring of local press

•Updating services offered by external companies/bodies

•Regular contact with relevant regulatory bodies, e.g. NEA, MOM

8)If there are changes in legislation or introduction of new legislation, the respective Manager shall keep each other informed by circulation of relevant information

9)The respective Manager shall also maintain a file on permits/licences which are under his/her purview.  

10)The respective permit or licence holders shall ensure that the permits or licences under their responsibility are renewed accordingly and an updated copy submitted to the EHS Officer for consolidation  and maintained in the organisation’s shared network.

11)Managers shall ensure that relevant information on legal and EHS requirements are communicated and understood by their staff through such means but not limited to:

• Work instructions during on-the-job training;
• Normal job duties;
• Circulation of internal information;
• Operational Control Procedure/Safe Work Procedure;
• Toolbox meetings, etc

12)Besides communication to staff, the Management shall also ensure that relevant information on legal and EHS requirements are communicated to interested parties through such means but not limited to:Meetings, circulars, e-mails, advertisements, etc.

The EHS Officer shall develop a plan to evaluate fulfilment of the organisation’s compliance obligations  on an annual basis or at shorter intervals through one or more of the following methods:

• monitoring of operational control procedures to ensure all the relevant requirements are being adhered to;
• monitoring of EHS programmes to achieve compliance, where the programmes are defined;
• conducting periodic monitoring and measurements;
• regular inspections by the responsible personnel; or
• carrying out compliance audits once every 12 months 

14)Where a non-compliance is discovered, it is the responsibility of the Manager to take the necessary follow-up action and raised an Investigation on Non-conformity and Corrective Action Report