EVALUATION OF
COMPLIANCE ON LEGAL REQUIREMENTS
PROCEDURE
1 PURPOSE:
The purpose of this procedure is to identify the legal and
other Occupational Health & Safety requirements so that the compliance
could effectively be ensured.
2 SCOPE:
This procedure is applicable to entire ABC Steel Mills Ltd.
(STEEL MILL) covering all the OH&S legal requirements.
3 RESPONSIBILITIES:
·
Executive Environmental, health & Safety
(EH&S) will be responsible for identifying and accessing legal and other
OH&S requirement in the premises.
·
Paramedic Officer will be responsible for
Medical examination (Hygiene cards).
·
Head of Department (HOD) Admin &HOD EHS will
be responsible to ensure that all the OH&S related requirements are
identified and complied.
4 PROCEDURE:
4.1 Legal Requirements
4.1.1 Hygiene Cards
·
Each permanentworker (Non-Management)in premises
has provided valid Hygiene cards under Section 23 of Factory Act 1934.
·
Semiannuallyentries are being recorded in the
month of January and July after examination by appointed factory doctor ensuring
that the worker is not suffering from any contagious or infectious disease.
·
A worker found to be suffering from any
contagious or infectious disease on an examination he/she shall be vaccinated
and inoculated against such disease(s) and the expenses are on behalf of
Organization as per STEEL MILL’s medical policy.
·
Industrial doctor of government visits
semiannually at STEEL MILL to verify the Hygiene cards and issue the
certificate if no observation found.
·
All hygiene cards and required documents are
maintained, shared as demanded, up-to-date and evaluated timely.
4.1.2 Radiation Protection
Sealed Radiation sources(SRS) in STEEL MILL aresited at two production
lines:
1.
Cold Rolling and Skin Pass Mill (CRSM)
2.
Push Pull Pickling Line (PPPL)
At CRSM and PPPL Thickness gauge (Am-241) and Density meter
(Ba-133)are used respectively, which used with the permission of Pakistan
Nuclear Regulatory Authority (PNRA). PNRA requires these facilities to submit
various documents as part of licensing application and during the lifetime of
the facility in order to ascertain that the facility is working safely and in
compliance with the regulatory requirements. STEEL MILL has acquired the
License for radiation facility in accordance with PNRA Ordinance No.III of 2001
and PNRA Regulations PAK/908, (License No.).We perform several tests for the
safety of workers working near SRS:
·
Leak test is regularly performed by Radiation
Protection Officer (RPO) monthly in accordance with the procedure(STEEL MILL-EH&S-SOP-008).
·
For determining the Doze rate, FILM & TLD
batches are provided to operators which are tested bimonthly and quarterly respectivelyfrom
M/s PINSTECH, Islamabad. Results are shared with respective Line In-Charge, add
the dose results limit in previous results of individual worker and monitor the
results that either It is in acceptable range or not and document all the
related information.
Note: Till now no FILM/TLD batches
exceeded their limit.
·
CBC blood test of operators (working near the
radiation area) is performed annually by:
a. Taking blood sample and send those samples to
Government registered laboratory for test.
b.
Results are compared with previous test results.
If the test results is out of the acceptable limit (20mSv/year as defined by
PNRA) then request to manager, to relocate the job task of that particular
worker.
STEEL MILL yearly (to fulfill the requirement of PNRA) renew
the License of radiation sources by sending license application form along with
renewal fee within 60 days if expiry date after which a late fee surcharge is
applicable as per PNRA Regulations
All the related information is documented, shared as
demanded, up-to-date and evaluated timely.
4.2 Other Requirements
4.2.1
Fire
Protection
STEEL MILL has acquired the portable and trolley type Fire extinguisher.
For a fire extinguisher to be effective, the following care
and exercised at STEEL MILL.
·
The extinguisher must be right for the type of fire
·
It must be located where it can be easily
reached
·
It must be in good working order
·
The fire must be discovered while it is still
small
·
The person using the extinguisher must be
trained to use it properly
At STEEL MILL we have:
·
Type A, B, C & Electrical Fire Extinguishers
– dry-chemical-powder (DCP) Gas
·
CO2 Electrical Fire Extinguishers –
Carbon dioxide (CO2) Gas
Type A, B, C & Electrical is used for Ordinary
combustible, Flammable Liquids and Gases, Electricity. Cleaning& Servicing is
performed semiannually (depends upon requirement) of fire extinguishers.
Inspection &verification of fire extinguishers is being
carried out monthly at STEEL MILL.
·
DCP Gas fire extinguishers areverification by
checking gauge:
ü
If the needle of the gauge is on the green side then
it is in working condition.
ü
If the needle of the gauge is on the red side
then it cannot be used further.
·
Co2 Gas fire extinguishers are verification
by measuring weight.
ü
Used/Expire Fire extinguishers are replaced
immediately.
4.2.2
Evacuation
Drill
Evacuation Drill is carried out annually at STEEL MILL to evaluate
the emergency response for Fire & Safety.
4.2.3
Factory
Act Laws
4.2.3.1 Cleanliness
Factory premises are kept clean by administration
department.
4.2.3.2 Ventilation and Temperature
Ventilation and Temperatures control system are well managed
& maintained to create the conducive working environment for STEEL MILL
Staff.
4.2.3.3 Lighting
Sufficient and suitable lighting, natural or artificial, and
both are provided.
4.2.3.4 Drinking Water
Clean drinking water is available at STEEL MILL from the
certified and recognized Food safety company.
4.2.3.5 Working Hours
Working are at STEEL MILL are not more than 48hrs. /week as
per law.
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