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BAPP GROUP OF COMPANIES ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) MANUAL BAPP Group of Companies Environmental Manual Issue No: 2 – 18 June 2015 Page 1 of 29 THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED OR COPIED

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Page 1: Quality Manual - BAPP · Web viewBAPP Group of Companies Manual – “Health and Safety Organisation and Arrangements”. BAPP Group of Companies recognises that training plays an

BAPP GROUP OF COMPANIES

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) MANUAL

BAPP Group of Companies Environmental Manual Issue No: 2 – 18 June 2015 Page 1 of 22THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED OR COPIED

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This Environmental Management System (EMS) Manual is the property of BAPP Group of Companies.

The contents of this manual are approved by Dean Cook BAPP Group of Companies Chairman.

Any subsequent amendments or re-issues will be made in accordance with BAPP Group Limited Procedure 002 Documents and Data Control.

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CONTENTS

Section Details Page No:

1. BAPP Group of Companies 51.1 Introduction to the Company. 51.2 Management, Health, Safety, Environment and

Communication Structure. 5

2. Scope of Application 6

3. Terms and Definition 6

4. Environmental Management System 74.1 General 74.2 Environmental Policy Statement 8

4.3 Planning 94.3.1 Environmental Aspects and Impacts 94.3.2 Environmental Legal and Other Requirements 94.3.3 Environmental Objectives, Targets and Programme(s) 10

4.4 Implementation and Operation 104.4.1 Resources, Roles, Responsibilities and Authority 104.4.2 Competence, Awareness and Training 124.4.2.1 Competence, Awareness and Training 124.4.2.2 MCP New Starter Induction Training 144.4.2.3 Sub-Contractors 144.4.3 Communication 154.4.3.1 Internal Communication 154.4.3.2 External Communication 154.4.4 Documentation 164.4.4.1 General 164.4.4.2 Environmental Management System (EMS) Manual 164.4.5 Control of Documents 164.4.6 Operational Control 164.4.7 Emergency Preparedness and Response 174.4.7.1 Documentation 174.4.7.2 Action in the Event of an Emergency or Breach of

Environmental Management Plan Measure. 174.4.7.3 Incident and Near Miss Reporting 184.4.7.4 Emergency Contact 184.4.7.5 Emergency Preparedness Information to Personnel 18

4.5 Checking 194.5.1 Monitoring and Measuring 194.5.1.1 General 194.5.1.2 Monitoring and Measuring of Processes 19

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Section Details Page No:4.5.1.3 Analysis of Data 194.5.1.4 Control of Monitoring and Measuring Devices 194.5.2 Evaluation of Compliance 194.5.2.1 Evaluation of Compliance with Applicable

Legal Requirements 194.5.2.2 Evaluation of Compliance with Other Requirements 204.5.3 Control of Non-Conforming Products 204.5.4 Control of Records 204.5.5 Internal Audits 204.6 Management Review 21

Document Management Record 22

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1. BAPP Group of Companies

1.1 Introduction to the Company

The BAPP Group of Companies founded in 1972 has now become the largest independent stockist and distributor of nuts & bolts and associated products in the UK.

The BAPP branch network covers the total supply throughout the UK from our twelve locations. As well as same and next day delivery to our OEM customer base, each branch has its own Tool and Fixing Centre.

The BAPP Group Contracts at BAPP Group Limited premises has vast experience in shipping throughout the world and can cater to any demands for both major and small construction projects. 1.2 Management, Health, Safety, Environment and Communication Structure

The BAPP Group of Companies Management, Health, Safety, Environmental and Communication Structure is detailed on BAPP Group Flowchart 001 “Management, Health, Safety, Environmental and Communication Structure”

This document is incorporated into the “BAPP Group of Companies individual “Controlled Document Suite” and is available on their computer network under "Health, Safety, Environmental and Quality Management System/Controlled Documents".

The company has the following elements within the BAPP Group of Companies:-

BAPP Group Limited BAPP Industrial Supplies (Leeds, Castleford & UK) Limited BAPP Industrial Supplies (Doncaster) Limited BAPP Industrial Supplies (Huddersfield) Limited BAPP Industrial Supplies (Hull) Limited BAPP Industrial Supplies (Lancs) Limited BAPP Industrial Supplies (Leicester) Limited BAPP Industrial Supplies (Mansfield) Limited BAPP Industrial Supplies (Preston) Limited BAPP Industrial Supplies (Scunthorpe) Limited BAPP Group Contracts Limited

Each company listed above is managed as singular companies independent of each other within the BAPP Group of Companies.

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2. Scope of Application

Stockholding and Distributor of Mechanical Fasteners.

Stockholding and Distributor of Mechanical Fasteners in accordance with National Highways Sector Scheme 3

Stockholding and Distributor of Mechanical Fasteners.

Stockholding and Distribution of BAPP Group Limited EN 14399-1 CE Marked High-strength structural bolting assemblies for preloading.

Stockholding and Distribution of BAPP Group Limited EN 15048-1 CE Marked Non-preloaded structural bolting assemblies.

Stockholding and supply tools safety equipment and clothing.

Our ISO 14001: 2004 scope and registration and Environmental Management System cover all areas of service.

3. Terms and Definition

Some “Terms and Definitions” used within section 4 are defined in BS EN ISO 14001:2004.

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4. Environmental Management System

4.1 General

The company has implemented an Environmental Management System that recognises the need for controlled processes in order to achieve the goals stated within the Environmental Policy Statement. This includes the interaction between processes and people, the effectiveness of those processes and the need to adequately control through monitoring and continual improvement, the relevance of the processes to the business. It is the responsibility of the Environmental Management System Representative to manage the Business Systems. The process sequence and interaction of the Environmental Management System within BAPP Group of Companies is as follows:-

Coding

= EMS Manual = BAPP Document = Process

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Resource ManagementInfrastructureTraining

PurchasingProcessesDocument ControlNonconforming ProductCorrective ActionPreventive Action

PlanningContract ReviewPurchasingClient Analysis

Customer AnalysisOperationsNon-conformancesCorrective ActionPreventive ActionSupplier Analysis

Management ResponsibilityCommitmentEnvironmental PolicyAuthority & CommunicationEnvironmental ObjectivesIdentify Environmental Aspect and Impacts.Legal & Other Requirement Compliance

Environmental Management System

Monitoring & MeasurementAnalysis of DataImprovement

Client Requirements Site Operations Completion

DocumentationPoliciesEnvironmental ManualProceduresFlowchartsFormsRecordsSupporting DocumentsStandardsDocuments Related to Statutory Requirements i.e.:-Acts & RegulationsApproved Codes of PracticesGuidance Documents

Product RealisationPlanningClient Related ProcessesProduction & Service Provision

ProcessesClient AnalysisInternal AuditsManagement ReviewLegal & Other Requirement ComplianceNon-conformancesCorrective ActionPreventive ActionSupplier Analysis

Processes

Management ReviewClient Analysis

Document ControlRecord Control

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4.2. Environmental Policy Statement

BAPP Group of Companies recognises its operation may impact on the natural and built environment.

The aim is to be successful and expand. In order to achieve this goal it needs places of work, people, plant and a process. These ingredients, however, can lead to Environmental Incidents.

BAPP Group of Companies therefore insists that Environmental aspects and impacts are considered in the same context and with the same priority and resources as all other business objectives.

With respect to this BAPP Group of Companies aim is through a management system integrated with Health, Safety and Quality Assurance to continually assess the environmental implications of its activities and seek the co-operation of all Clients, Suppliers and BAPP Group of Companies employees in minimizing any adverse effects.

To achieve these aims and objectives BAPP Group of Companies will: -

Work within the framework of existing and impending environmental law. Insist that our business partners adhere to all relevant legislation and

international agreed conventions as an absolute minimum. Comply with applicable legal requirements and other requirements that relate

to BAPP Group of Companies environmental aspects. Develop and work within the framework of an Environmental Management

System (EMS). Identify environmental hazards, aspects and impacts Seek to minimize to a reasonably practicable level adverse effects on the

environment by minimizing waste, efficient use of energy and prevention of pollution.

Strive to achieve measured continual improvement in relation to the BAPP Group of Companies Environmental Management System.

Communicate our policies to both Customers and Suppliers. Encourage and assist when possible our Suppliers in raising standards. Set at the annual Management Reviews environmental objectives and targets

that can be measured to facilitate effective and efficient review. Set clear responsibilities for Environmental protection for all personnel within

BAPP Group of Companies. Ensure all personnel are responsible and committed to the formulating,

amending, reviewing and implementing their aspects of this policy. Carry out proactive as well as reactive monitoring of activities via Warehouse

Inspections, System Audits and analysing statistics. Seek advice and help from Environmental professionals and organisations Develop the Environmental Management System in line with BS EN ISO

14001:2004. Review this Policy at least 12 months after date of issue.

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4.3 Planning

4.3.1 Environmental Aspects and Impacts

The BAPP locations Operational Procedure " Risk Assessment Procedure” is the mechanisms to be used to ensure suitable and sufficient risk assessment for Health, Safety and Environmental hazards, impacts and subsequent risks are undertaken.

It is the responsibility of BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager in the role of implementing and maintaining BAPP Group of Companies Environmental Management System to identify BAPP Group of Companies significant “Environmental Aspects” for BAPP Group of Companies activities, products and services and then determines the significant “Environmental Impacts” that BAPP Group of Companies will cause on the environment.

In addition to the company identified “Environmental Aspects and Impacts” which are taken into account in establishing, implementing and maintaining the “Environmental Management System”. BAPP Group of Companies will review the “Environmental Aspects and Impacts” for individual locations and tasks and include them within the relevant Risk Assessment. 4.3.2 Environmental Legal and Other Requirements

Protection of the environment is becoming more and more involved with every Industry in the UK. In order to maintain protection, legislation is ever increasing and as such BAPP Group of Companies are committed to being aware of and compliance with the Environmental, Health and Safety, Legal and Other Requirements.

The BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager will be responsible for reviewing current and future Environmental, Health and Safety, Legal and Other Requirements to ensure BAPP Group of Companies is continuously compliant.

A list of relevant “Environmental Legal and Other Requirements” is maintained by the BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager. This list as well as where available the specific document are readily available on request to BAPP Group of Companies personnel.

The BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP QA Group Manager are responsible for updating and maintaining the list of relevant “Environmental Legal and Other Requirements”.

Review of “Environmental Legal and Other Requirements” as “External Controlled Documents” will be undertaken as detailed in Operational Procedure 02 – Document and Data Control.

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4.3.3 Environmental Objectives, Targets and Programme(s)

The Management Review meeting will be used as one of the means of ensuring that Health, Safety, Environmental and Quality aims and objectives are established including (where applicable) those needed to enhance BAPP Group of Companies commitment to the prevention of pollution, aid “Continuous Improvement” and meeting or exceeding Customer’s requirements and expectations.

In addition the “Environmental Objectives and Targets shall take into account “Environmental Legal and Other Requirements” which are applicable to BAPP Group of Companies and the “Environmental Aspects and Impacts” identified by BAPP Group of Companies.

4.4. Implementation and Operation

4.4.1 Resources, Roles, Responsibilities and Authority

BAPP Operational Procedure OP01 – “Organisation Chart, Responsibilities and Authority” identifies the job titles within BAPP locations.

This procedure details individual job descriptions, roles, responsibilities and authority.

Responsibility and Authority

The BAPP Group of Companies Chairman and Managing Directors are all responsible for all Management Systems. The following are specific responsibilities:-

BAPP Group of Companies Chairman and Managing Directors

Overall management of the business.Corporate decisions.Major contracts, approval of quotes and purchases.Liaison with Clients and Suppliers.Finance & Resources.Business Systems including Environmental, Health and Safety, and QualityAssigning a Management Representative for Health, Safety and Quality Assurance.Liaising with the BAPP Group of Companies Health, Safety, Environmental & Quality Assurance Advisor.Liaising with other interested parties. Managers

Contract reviews and negotiations.Contract variations.Minor contracts and Client’s Orders or Instructions.Organising, planning, implementing, monitoring and review of BAPP location issues.BAPP location operations.Business Development.Purchasing.Training.

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Recruitment.Monitoring and Supervision.BAPP location records production and retention.Liaising with Clients and Suppliers.Liaising with the BAPP Group of Companies Health, Safety, Environmental & Quality Assurance Advisor. Liaising with other interested parties.To purchase all plant, materials and goods, within the required timeframeTo hire if necessary all specialist plant, within the required timeframe Health, Safety, Environment and Quality Assurance Advisor & BAPP Group QA Manager

Management of the Business Management Systems including Environmental, Health and Safety, and Quality.Internal Environmental, Health and Safety, and Quality AuditsDocument and Data production and controlManagement ReviewEmployee Competence and Training record administratorCOSHH database administratorAnalysing and providing reports on Non-Conformances, Customer and Supplier Communications and Complaints, Accidents and Incidents and Health, Safety, Environmental, Health and Safety, and Quality Action Plan status.Monitoring Supplier Assessments are carried out annually.Liaising with other interested parties. Liaising with BAPP Managing Directors, Managers and BAPP location personnel

Supervisors

Ensuring Resources are suitable and available for effective work execution.Organising, planning, implementing, monitoring of BAPP location activities.Liaison with Clients and Suppliers.Records production and retention.

Administration

PurchasingLiaison with Clients and SuppliersInvoicing

Operatives

Receiving, stocking, picking and dispatching Industrial Fasteners, Tools, Safety Equipment and Clothing in a safe and environmentally friendly manner and also to Clients' satisfaction.

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Management Representative and Deputy

BAPP location Managing Director or Branch Manager or in his absence the BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager is the Management Representative for the Environmental Management System and as such has the authority and responsibility for ensuring that the requirements of the Environmental Management System and other Business Systems are established, implemented and maintained.

This includes reporting to other Senior Management on the performance of the Environmental Management System and other Business Systems together with any recommendations for improvement and promoting awareness of Client requirements.

4.4.2 Competence, Awareness and Training

4.4.2.1 Competence, Awareness and Training

BAPP Group of Companies ensures that all personnel performing work are competent. This is based on appropriate skills, education, training and experience.

All personnel employed by BAPP Group of Companies will have the appropriate experience or undergo the necessary training to perform their job satisfactorily, safely and cause minimum effect on the Environment.

Previous experience, knowledge and experience are considered when assigning specific tasks to personnel.

Employee competence awareness and training is monitored and recorded within specific BAPP locations or by the Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager.

The records identify what competence has been achieved, what is required, what would be desirable, what is not required and when refresher training is required.

The specific procedure for achieving competence and authorisation to carry out tasks can be found in:-

BAPP Group of Companies Manual – “Health and Safety Organisation and Arrangements”.

BAPP Group of Companies recognises that training plays an important part in the effective development of human resources. Environmental training forms part of the overall strategy. Thus, BAPP Group of Companies will ensure that every person carrying out work for BAPP Group of Companies knows the Environmental requirements relating to his job. Often these will be general, but for certain groups or individuals there will be specific training requirements.

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The Environmental training needs will cover five categories:-

1. Legal requirements.2. Environmental Aspects and Impacts associate with the work activities.3. Environmentally friendly working methods.4. Environmental Incident prevention and protection techniques.5. BAPP location specific requirements.

Personnel carry out working for BAPP Group of Companies will be assessed on a continuous basis for their individual level of competence and level of skill needed for their normal assigned tasks. Necessary, statutory, refresher, BAPP Group of Companies desired training will be determined and arranged by the BAPP Group of Companies Managing Directors, Managers and/or Health, Safety, Environmental and Quality Assurance Advisor. All aspects of training and/or competence assessment will include the necessary information and instructions relating to the Environment.

The level of training and/or competence assessment required will be based on the known environmental hazards, degree of risk and the impact of their undertakings on the Environment.

Training and/or competence assessment will be carried out either internally using BAPP Group of Companies personnel or by external providers. The type of training and/or competence assessment will be one of the following: -

Formal training course. On job training/supervision. Informal course. Formal qualification. BAPP Group of Companies assessment.

Training in Environmental matters forms an integral part of the company induction and toolbox talks provided for each person carrying out work for BAPP Group of Companies.

Any additional training on general or specific Environmental matters and instruction associated with the use of equipment is provided by courses and practical exercises either in house or by external providers.

Records of training completed or required and/or competence assessments will be retained at specific BAPP locations or by the Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager on the individuals Competence and Training Record.

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Instructions in the safe and correct operation of work equipment and systems of work that will cause minimum impact on the Environment will be in the forms of:-

Formal course attendance. Course notes and handouts. Manufacturers’ instruction books and leaflets. Hire company instruction books and leaflets. Verbal instructions from Line Managers and Supervisors. Written instructions in the form of a Method Statement (where risk assessment

identifies it necessary). BAPP location/ department meetings/talks. Physical demonstration of equipment by suppliers. Physical demonstration of equipment by Line Managers and Supervisors.

4.4.2.2 BAPP Group of Companies New Starter Induction Training

All new personnel engaged by BAPP Group of Companies to carrying out working for BAPP Group of Companies will attend the course as soon as practical after starting with BAPP Group of Companies. It is the BAPP location Managing Director or Manager’s responsibility to ensure the Induction Training is carried out. BAPP Group of Companies Form F12.1 - “Induction Checklist” will be used and completed by the BAPP location Managing Director or Manager or designated person conducting the training.

The Induction Checklist will serve as an aid memoir during training and record of training after completion.

The induction training will cover such issues as: -

BAPP location policies including Health, Safety, Environmental and Quality Assurance policies.

BAPP location documentation. Duties of personnel carrying out work for BAPP Group of Companies. Reporting procedures. Means of Communication and Organisational Structure. BAPP location Environmental Awareness. BAPP Location rules. Access and egress from/to site. Environmental Emergency procedures.

4.4.2.3 Sub-Contractors

If BAPP Group of Companies do use Sub-Contractors for specific projects it will be the BAPP location Managing Director and Manager’s responsibility to ensure that the Sub-Contractors personnel have the “Competence, Training and Qualifications” to undertake the assigned tasks. This will include relevant aspects of Environmental requirements.

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The minimum level of “Competence, Training and Qualifications” that Sub-Contractor personnel must have will be that of BAPP Group of Companies personnel involved at the same location and also in line with statutory and other requirements.

4.4.3 Communication

4.4.3.1 Internal Communication

Regular meetings between BAPP location Managing Director and Managers ensure effective communication and consultation takes place regarding all matters including management and application of Business Systems.

The Company adopts an open door policy with communication from Managing Director down to all personnel and vice versa.

BAPP Group of Companies is divided up into individual locations operating independently of each other with a Managing Director, Manager, Supervisors and Warehouse personnel all work closely together with the objective of “Purchasing, Stocking, Picking and Dispatching” Industrial Fasteners, Tools and Safety Equipment and Clothing” safely and in an environmentally friendly manner.

This high managerial presence is enhanced by frequent site tours from BAPP Group of Companies Chairman as well as audits and site visits from the Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager. This level of visibility ensures that “Communication and Consultation” is constant.

4.4.3.2 External Communication

The following “External Interested Parties” are as follows:-

Clients. Environment Agency. Health and Safety Executive or Local Authority Enforcing Officers. Accreditation/Registration and Membership Bodies. Other Companies. Third Parties associated with the BAPP locations.

The most appropriate method for receiving and dealing with documentation, correspondence from “External Interested Parties” and also responding to the specific “External Interested Parties” shall be determined by the BAPP location Managing Director or Branch Manager who will be involved with the “External Interested Parties” when dealing with relevant subjects.

The BAPP location Managing Director or Branch Manager will be supported by other BAPP Group of Companies personnel when required and also by the BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager.

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BAPP locations will communicate their identified significant Environmental Aspects to “External Interested Parties” if requested to do so or if the BAPP location feels the information should be made available to others.

It will be the responsibility of the BAPP location Managing Director or Branch Manager communicating with the “External Interested Parties” to determine how and to who the information should be communicated to.

BAPP location identified significant Environmental Aspects are available from the BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager.

4.4.4 Documentation

4.4.4.1 General

BAPP Group of Companies has established an Environmental Policy Statement, which includes some of its Environmental Objectives. Other objectives are available on each BAPP location’s Health, Safety, Environmental and Quality Objective document which is reviewed annually at the BAPP Location’s Management Review.

The BAPP Group of Companies Controlled Document Suite which is the basis of its management systems for Quality, Safety, Environment and Business consists of:-

Policies for Safety, Environment and Quality Manuals for Safety, Environment and Quality Procedures Flowcharts Forms

The documented system is supported by IT capability.

4.4.4.2 Environmental Management System (EMS) Manual

The Environmental Management System is documented and presented in the form of this Environmental Management System (EMS) Manual.

The Environmental Management System (EMS) Manual communicates the Environmental Management System policy, management responsibility, Environmental Management System requirements and outlines the procedures required for controlling the Environmental Aspects and Impacts of work and service of BAPP Group of Companies.

4.4.5 Control of Documents

BAPP locations Managing Directors and Branch Managers assisted by BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor are responsible for managing documents deemed as "controlled" documents. This is carried out in accordance with BAPP locations Operational Procedure OP02 – “Documents and Data Control”.

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4.4.6 Operational Control

The planning focuses on defining what processes, documentation, training and resources are needed to meet effectively and efficiently the company's policies, aims, objectives, strategy, legislative compliance and intent, minimising the Environmental Impact of identified Environmental Aspects as well as the Client’s requirements and expectations and constantly looking at ways of improvement.

The ultimate aim is for the BAPP Group of Companies to provide “Industrial Fasteners, Tools, Safety Equipment and Clothing for a fair price safely with minimum impact on the Environment and to Client's satisfaction. To help achieve this, the company uses a combination of:-

Controlled Documents. Competent Employees. Personnel with various skills and knowledge working as a team. Reliable resources, tools and equipment. Supervision. Monitoring and Auditing. Management Reviews either formal or informal. Identifying Environmental Aspects both at Company level and at BAPP location

level. Support material such as Risk Assessments and Method Statements. Specialist Services (when necessary). Training, Information and Instructions. BAPP location Inductions. Communication with BAPP Group of Companies personnel and interested

Third Parties. Continuous contact with Clients and Client's Representatives.

4.4.7 Emergency Preparedness and Response

4.4.7.1 Documentation

Where deemed necessary BAPP locations will have written documentation to identify potential “Environmental Impacts and Incidents” and the method of mitigating or controlling them.

The documentation can be one of the following:-

BAPP location Operational Procedure. i.e. - Operational Procedure OP15 - “Accident and Incident Reporting Procedure”.

Risk Assessment and Method Statement. Action Plan or Sheet.

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4.4.7.2 Action in the Event of an Emergency or Breach of Environmental Management Plan Measure.

In the case of any identified incidents or concerns associated with environment the action to be taken is:-

BAPP location personnel aware of situation must take what immediate action is necessary to minimise the impact.

BAPP location personnel must report it immediately to the BAPP location Managing Director and/or Branch Manager, BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager.

The BAPP location Managing Director and/or Branch Manager, BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager will inform the relevant interested Third Parties.

Under the supervision of BAPP location Managing Director and/or Branch Manager, BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager the BAPP location personnel will take what action they are able to take to rectify the situation.

The BAPP location Managing Director and/or Branch Manager and the BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager will decide if the incident requires an incident investigation and if so this will be conducted by the BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or BAPP Group QA Manager who will produce a report.

4.4.7.3 Incident and Near Miss Reporting

All environmental incidents and near misses will be recorded on the BAPP location Accident and Incident Report Database.

All environmental incidents to be notified as soon as practicable to interested Third Parties.

4.4.7.4 Emergency Contact

The BAPP location Managing Director and/or Branch Manager will provide a list of “Out of Hours” contact numbers to be used in an emergency to relevant people or Third Parties.

4.4.7.5 Emergency Preparedness Information to Personnel

The BAPP location Managing Director or Branch Manager, BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor and/or

BAPP Group QA Manager will ensure that as part of the BAPP location Induction

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process all personnel are informed of the BAPP location Emergency Procedures. This topic at various intervals will be used as an item to be discussed at Safety and Environmental Briefs.

It will be the BAPP Group of Companies Health, Safety, Environmental and Quality Assurance Advisor’s and/or BAPP Group QA Manager’s responsibility to monitor the “Emergency Preparedness” and ensure it is always up to date and takes into account changes.

4.5 Checking

4.5.1 Monitoring and Measuring

4.5.1.1 General

Measurement, analysis and improvement processes namely site visits, process supervision and monitoring, Management meetings and reviews, data recording and analysing, Client and supplier communications and recording and analysing of significant communications including Client satisfaction, actions, non-conformances, customer complaints, supplier issues and internal audits are used by BAPP locations in its efforts to provide “Industrial Fasteners, Tools, Safety Equipment and Clothing for a fair price safely with minimum impact on the Environment and to Client's satisfaction.

4.5.1.2 Monitoring and Measuring of Processes

Monitoring and measuring of processes takes the same format of supervision, BAPP location visits, Client and supplier communication, employee communication, internal and external audits, data collation and analysing, Management meetings, Management Review and frequent reports.

4.5.1.3 Analysis of Data

Data on Client and supplier communications, customer satisfaction, audit findings, corrective and preventive actions, customer complaints, accidents and incidents are recorded and analysed and reports to BAPP location Managing Director and/or Branch Manager are produced.

4.5.1.4 Control of Monitoring and Measuring Devices

Any equipment used to ensure the product realisation conforms to Client agreed critical specifications or safety of personnel would be identified as calibrated equipment.All equipment identified as Calibrated Equipment will be subject to testing at frequencies determined by BAPP locations or in line with manufacturers’ recommendations.

Equipment, which is not used for checking critical specifications but is used for verification or non-critical measurements, will be classed as equipment used for verification only.

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4.5.2 Evaluation of Compliance

4.5.2.1 Evaluation of Compliance with Applicable Legal Requirements

Internal audits are carried out to verify the Environmental Management System (EMS) and the systems requirements are being complied with and conform to statutory and other legislative requirements.

Internal audits are carried out in accordance with BAPP location Operational Procedure OP11 – “Internal Audits”.

4.5.2.2 Evaluation of Compliance with Other Requirements

In addition to checking for compliance with “Legal Requirements”, internal audits are carried out to verify the effectiveness of Business Management Systems which includes the Environmental Management System (EMS) and that the systems requirements are being complied with and conform to standard requirements, BAPP location requirements and specific Client requirements.

Internal audits are carried out in accordance with BAPP location Operational Procedure OP11 – “Internal Audits”.

4.5.3 Control of Non-Conforming Products

Non-conformances may be found in processes carried out products supplied, application of procedures, flowcharts or manuals and compliance with standards, Approved Codes of Practice, Statutory and other legislative requirements, BAPP location requirements and specific Client requirements.

Individuals may identify these during supervision, monitoring or inspection, through communication with Clients (Customer Complaints) or via internal or external audits.

The process for dealing with non-conformances and subsequent corrective and preventive actions is detailed in BAPP location Operational Procedure OP08 – “Control of Non-Conforming Products” and Operational Procedure OP13 – “Corrective, Preventive, Continuous Improvement Actions, Customer or Supplier Complaint”.

4.5.4 Control of Records

Records are maintained to demonstrate that the requirements of legislation, standards, business needs and Clients requirements are met and where necessary to monitor effectiveness of specific aspects, systems, procedures and processes.

All records must remain legible, easily identified, stored in a safe environment and readily retrievable.

Location, retention times, filing system and disposition of records will be identified either in BAPP location Operational Procedure OP10 - “Records”, individual procedures, flowcharts.

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4.5.5 Internal Audits

Internal audits are carried out to verify the effectiveness of Business Management Systems which include the Environmental Management System (EMS) and that the systems requirements are being complied with and conform to standards, statutory and other legislative requirements, BAPP location requirements and specific Client requirements.

Audits are recognised as a management tool and used as a proactive means of checking effectiveness of processes, compliances, communication, identifying areas of Continuous Improvement, training and providing recommendations.

There is always the possibility of non-conformances and observations. This is the reactive aspect and as these are identified they will initiate corrective and if necessary preventive actions.

Internal audits are carried out in accordance with BAPP location Operational Procedure OP11 – “Internal Audits”.

4.6 Management Review

Annually the BAPP location Managing Director and/or Branch Manager will carry out a Management Review of the Business Management Systems, which includes Health, Safety, Environmental and Quality Assurance Systems. The review looks at the previous policies, aims, objectives and targets and sets new ones for the next twelve months.

Management Reviews will be carried out in accordance with BAPP location Operational Procedure OP14 – “Management Review”.

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DOCUMENT MANAGEMENT RECORD

DOCUMENT TITLE: Environmental Management System (Ems) Manual DOCUMENT NO: BAPP Group of Companies Manual 003PREVIOUS REVIEW DATE: 18 June 2015NEXT REVIEW DATE: 17 June 2018

DOCUMENT ISSUE STATUS

Issue Date Notes Originator Authorised For Use

1 10 March 2014

First Issue Fred Maddick

Wayne Grealey

2 18 June 2015

Amendments to incorporate BAPP Group QA Manager

Fred Maddick & Alister Smith

Wayne Grealey

BAPP Group of Companies Environmental Manual Issue No: 2 – 18 June 2015 Page 22 of 22THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED OR COPIED