Ehsms Gap Analysis

8/10/2019 Ehsms Gap Analysis

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SUMMARY OF THE OUTCOME OF EHSMS GAP ANALYSIS OF SUPER CEMENT

The AD EHSMS Registered Practitioners (Grade A) of Gulf Test Safety Consultancies has

performed the gap analysis through reviewing the existing IMS (OHSAS 18001:2007 & ISO

14001:2004) and through interview with Mr. Vivek on the current environmental, health &safety management system, practices and documentation of Super Cement. Form C of the

AD EHSMS has been used as checklist for the performance of this gap analysis, with

reference to ZonesCorp requirements.

Based on the requirements of AD EHSMS Regulatory Framework, the consultant collected

sufficient information to describe the current position of Super Cement in terms of

compliance with Abu Dhabi EHSMS requirements.

For detailed information on the results of this gap analysis, refer to followingEHSMS Gap

Analysis

1) EHS Manual

An EHSMS Manual will have to be developed by SUPER CEMENT which addresses the

requirements of AD EHSMS RF and ZonesCorp, with the assistance of assigned GTS

consultant.

2) EHSMS Procedures

The following procedures have been identified to be necessary in demonstratingSUPER CEMENTs conformance to AD EHSMS RF requirements & ZonesCorp:

Targets & Objectives Procedure.

Legal Requirements Compliance Procedure.

Risk Management Procedure.

Management of Contractors Procedure.

Emergency Management Procedure.

Management of Change Procedure.

Competence, Training & Awareness Procedure.

Hazard, Near-Miss, Incident Reporting & Investigation Procedure.

Communication & Consultation Procedure.

Operational Control Procedure.

Internal Audit & Inspection Procedure.

Nonconformity, Corrective & Preventive Action Procedure.

Performance Monitoring & Reporting Procedure.

Document & Records Control Procedure.

Management Review Procedure.


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3) Forms & Records

GTS consultant recommends also the development of forms and generation of the

following minimum records:

Records of education, training, skills & experience of personnel.

Records of training provision and the evaluation of training effectiveness.

Records of EHS monitoring & measurement.

Records of calibration & maintenance activities.

Records of periodic evaluation of compliance to legal requirements.

Records of compliance to legal and other requirements.

Records of incident investigation & analysis.

Records of the results of corrective & preventive action taken.

Records of internal audit & inspections. Records of EHS performance monitoring & measurements.

Records of EHS management systems review.

4) Other Documentation

Specific Operational Control Procedures and SOPs will be developed (as practicable

and necessary) based on the results of risk assessment of SUPER CEMENT LLC.

5) Existing Gaps

Although the entity already have HSE documents based on ISO 14001 & OHSAS

18001, the entity has not yet developed a documented manual or procedures which

specifically addresses AD EHSMS requirements.

SUPER CEMENT should develop an EHSMS document structure consisting of the EHS

manual, procedures, forms/templates, and SOPs in order to demonstrate

compliance to EHSMS document requirements.

The scope of the entitys HSE management system is stated in the current manual.

However, the same scope is not yet stated in EHSMS specific manual.

The entity has an existing Environmental Policy and H&S Policy which was developed

in compliance with the requirements of ISO14001:2004 and OHSAS 18001:2007

standards. There is no specific EHS Policy in place which addresses the requirements

of AD EHSMS RF.

The entitys top management has not yet authorized and approved an EHS Policy

statement.


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Although the entity already has an existing environmental and H&S Policy

statements, there is no way to assess whether the policy is appropriate to the nature

& scale of the entitys risks since the entity doesnthave an established EHS Policy.

SUPER CEMENTs top management should ensure that its integrated EHS Policy is

appropriate to the nature & scale of its environmental impacts & OH&S risks. It

should contain a commitment towards prevention of pollution, incidents and ill-

health; enhancement of employee health & well-being; compliance to legal

requirements; setting, monitoring & reviewing its EHS objectives & targets; provision

of resources; and must ensure that the policy is reviewed periodically.

There is no evidence that the integrated EHS Policy has been communicated to all

stakeholders

There is no way to assess that the policy of the entity has been providing reference

to AD EHSMS & Sector Regulatory Authoritys EHS Policy since the entity doesnt

have its own existing EHS Policy.

The entity has not yet developed a procedure for defining and controlling its EHS

roles & responsibilities.

There is no structured process for communicating the roles & responsibilities of

employees.

The entity doesnt have a defined process for evaluating the performance of the

employees and measuring employees conformance to their defined roles &

responsibilities.

The entity has a documented procedure for environmental objectives, targets and

programs. However, it doesntcover the need to have objectives and targets related

to health & safety based on AD EHSMS requirements.

SUPER CEMENT should develop and prepare a documented procedure entitled,

Objectives, Targets & Programs Procedure.

EHS Committee needs to be established.

The entity has not yet established, documented and communicated its EHS Targets &

Objectives. SUPER CEMENTs top management and EHSMR, in coordination with its

EHSMS Committee, should establish its own measurable EHS Targets & Objectives

and document it.

When developing its own EHS Targets & Objectives, SUPER CEMENT should ensure

that these targets & objectives incorporates requirements of its EHS Policy, legal

requirements, results of its environmental impacts & OHS risk assessments, etc.


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SUPER CEMENT should develop its own EHS management programs necessary for

ensuring that their defined EHS targets & objectives are to be achieved.

SUPER CEMENT should develop and prepare a documented procedure entitled,

Legal Requirements Compliance Procedure, which also addresses compliance with

environmental laws and AD EHSMS requirements.

SUPER CEMENT should identify all applicable legal &other requirements during the

environmental impacts & OH&S risk assessments; and should prepare & maintain a

Legal Requirements Compliance Register.

SUPER CEMENT should assign specific person or department who will be responsible

for ensuring the entitys compliance to legal requirements and that controls are in

place for ensuring the validity and effectiveness of the compliance.

There is no process or evidence how the applicable legal requirements are

communicated to stakeholders. SUPER CEMENT should incorporate in the

documented procedure how the applicable legal requirements are to be

communicated to all stakeholders.

The entity currently has existing documented procedures for Environmental

aspects/impacts and OH&S hazards/risk assessment based on ISO 14001 & OHSAS

18001. However, SUPER CEMENT should develop & prepare an integrated procedure

for environmental impacts & OH&S risk identification, assessment and

determination of control based on the requirements of AD EHSMS and ZonesCorp.

The entity has not yet demonstrated and ensured that risk management is an

integral part of management and embedded in the entity culture and practices

The entity has not yet performed and documented its environmental impacts and

OH&S risk assessments.

SUPER CEMENT to define risk assessment methodologies in its documented

procedure based on AD EHSMS RF and ZonesCorp risk assessment requirements.

SUPER CEMENT should include in its risk assessment procedure the required steps in

performing risk assessment, such as identifying all EHS hazards in the workplace,

assessing each hazards, formulating a management program to reduce the risk to

ALARP (As Low As Reasonably As Possible) level, reviewing the program on a regular

basis and incorporating the management of change.

The entity has not yet developed a risk assessment procedure that includes all other

requirements for consideration in the performance of risk assessments.

SUPER CEMENT should incorporate in the risk assessment procedure other

requirements to be considered in the performance of risk assessment, e.g. routine &non- routine activities of persons having access to the workplace; supply chain &


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contractor undertakings; human behavior; hazards outside the workplace capable of

adversely affecting the environment and/or health & safety of workers; potential

risks to persons not in the companys employment; plant, equipment, substances

and materials at the workplace; the design of work areas, processes, work

organization and operating procedures.

SUPER CEMENT to include the application of environmental control hierarchies to its

risk management procedure based on AD EHSMS RF and ZonesCorp requirements.

SUPER CEMENT should perform an initial EHS review on all its existing processes and

services in order to determine the environmental impacts, which is to become part

of the overall EHS risk management.

SUPER CEMENT should develop and document the appropriate operational or

process safety control measures (if applicable) depending on the results of the risk

assessments.

SUPER CEMENT should develop a documented procedure for Management of

Contractors. The Management of Contractor Procedure should include specific

steps in the overall management of contractor process.

SUPER CEMENT should develop a documented Emergency Management Plan or

procedure which describes its emergency preparedness & response actions in the

event of an emergency.

SUPER CEMENT should include in its Emergency Management Plan all the risk-

based emergency response which is: threat-specific, facility-specific, appropriate

support/functional plans.

SUPER CEMENT should plan and periodically implement its emergency response &

management test & exercises, which is to become part of its Emergency

Management Plan.

SUPER CEMENT should develop Standard Operating Procedures (SOP) necessary in

implementing its EHS management system and operational control measures.

SUPER CEMENT should ensure that specific SOPs are developed which also addressesall matters related supply chains, (e.g. purchase of goods, equipment and services)

as necessary & practicable.

SUPER CEMENT should ensure that SOPs contain stipulated operating criteria or

instructions, where their absence could lead to an increase in EHS risks.

SUPER CEMENT should develop a Management of Change Procedure which would

clearly specify the entitys methods of Management of Change.


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SUPER CEMENT should ensure that the documented procedure for Management of

Change addresses the requirements for an analysis of change in location, equipment

and operating conditions for any potential hazards.

SUPER CEMENT should ensure that the EHS Training Procedure is developed to

include the requirements of AD EHS RIMechanism 07 and Mechanism 08

SUPER CEMENT should ensure that its documented training procedure addresses the

requirement and processes for identifying and evaluating the EHS training needs.

SUPER CEMENT should specifically define its process for training needs analysis and

the development of EHS Training Matrix. Trainings identified: (1) EHSMS

Awareness; (2)EHS Roles & Responsibilities; (2) EHS Emergency Response &

Management; (3) EHS Inductions (generic & site-specific); (4) EHS consequences of

non-conformance to EHS procedures; (5) Other relevant subjects related to EHS; and

(6) Specialized tasks-specific EHS trainings.

SUPER CEMENT should ensure that its competency procedure addresses the

requirements and processes for identifying and evaluating its EHS competency

requirements, which includes: (1) relevant EHS competencies; (2) task-specific

competencies; (3) methods for assessing competencies; (4) recording competencies;

and (5) maintaining & improving competencies.

There is no evidence that the entity has documented and implemented the EHS

minimum requirements required for incident investigations.

SUPER CEMENT should ensure that its EHS Hazard, Near- miss, Incident Reporting &

Investigation Procedure addresses the requirements and processes for the

following minimum requirements: (1) recording, investigating & analyzing EHS

incidents; (2) Investigations carried out by competent persons in consultation with

relevant stakeholders; (3) Investigations are carried out in a timely manner; (4)

Determining the root-cause of an incident; (5) Identifying opportunities for

corrective and preventive actions; and (6) Communicating the results of the

investigations to relevant stakeholders.

There is no evidence that the entity has documented and implemented the EHSminimum requirements for incident reporting.

SUPER CEMENT should ensure that its EHS Hazard, Near- miss, Incident Reporting &

Investigation Procedure addresses the requirements and processes for the

following minimum requirements: (1) hierarchies, time-tables and responsibilities for

reporting incidents; (2) Internal EHS performance and incident reporting

requirements; (3) External EHS performance and incident reporting requirements

(i.e. EHS incidents to SRA/CA as required, quarterly EHS performance to SRA, annual

3rd party external compliance audit results to SRA/CA, requirements of Mechanism 6

and other legal & regulatory reporting requirements); (4) Requirements outlined inCA permits, licenses, certificates, etc; (5) Requirements outlined in approved EHS


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plans & studies; and (6) Requirements outlined in relevant AD EHS Regulatory

Instruments.

The entity currently has a documented procedure for communication based on the

requirements of ISO 14001 & OHSAS 18001and not the requirements of AD EHSMS

and ZonesCorp

The entity doesnt have a documented procedure for EHS Consultation.

The entity doesnt have a documented procedure for EHS inspections.

The entity doesnt have a documented procedure for EHS Performance Monitoring.

The entity has not yet fulfilled the minimum requirements for EHS monitoring.

Ehsms Gap Analysis

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