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Environmental Policy Manual

Scope:

This Policy Manual has been constructed to address the specific requirements of the international standard ISO 14001 Environmental Management System in relation to the manufacture and supply of precision machined and finished components and assemblies.

ALM Products Limited is a one-site facility based at Grindon Way, Heighington Lane Business Park, Newton Aycliffe, County Durham, DL5 6SH.

Ordnance Survey Grid Reference: NZ 273 221 GB The site has a total area of 950 sq. metres including factory and office accommodation.

Compiled, issued and authorised by:

Alan Corsie (Quality & Environmental Manager)

Approved by:

Tony Thompson (Managing Director)

Date: 5th September 2012

Distribution: All Employees, as per document control register

ALM Products Ltd Environmental Policy Manual EM001/ISS.3

05/09/2012

Please note that this document is not controlled when printed P a g e | 1


Contents Table

4.1 GENERAL REQUIREMENTS 4.1 General requirements

4.2 ENVIRONMENTAL POLICY 4.2.1 Environmental Policy

4.3 PLANNING 4.3.1 Environmental Aspects and Impacts

4.3.2 Legal Requirements – Identification and Compliance

4.3.3 Objectives, targets and programme(s)

4.4 IMPLEMENTATION AND OPERATION

4.4.1 Resources, roles, responsibility and authority

4.4.2 Competence, training and awareness

4.4.3 Communication

4.4.4 Documentation

4.4.5 Control of documents

4.4.6 Operational control

4.4.7 Emergency preparedness & response

4.5 CHECKING 4.5.1 Monitoring and measurement

4.5.2 Evaluation of compliance

4.5.3 Nonconformity, corrective and preventive action

4.5.4 Control of records

4.5.5 Internal audit

4.6 Management review Management review meetings, inputs and outputs


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4.1 General requirements

An environmental management system has been established, implemented, documented,

maintained and is continually improved in accordance with the requirements of ISO 14001:2004

in the form of this manual and related procedures.

The scope of the environmental management system is defined in page 1 of this document.

See next page for policy and objectives statement


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4.2.1 Environmental Policy & Objectives Statement

ALM Products Ltd. is fully committed to the principles of the ISO 14001 Environmental

Management System (EMS), as defined in the company’s Environmental Policy Manual and

supporting procedures /documentation.

The company shall use the Environmental Management System documentation as the foundation on which to build employees education and knowledge via training and awareness programs aimed at the identification and understanding of the environmental impact of their activities. The company will endeavor to promote its environmental policy to suppliers, contractors, clients and other interested parties via website information and other forms of applicable communication media.

All relevant legal and contractual requirements related to environmental impact shall be identified, complied with and included within the EMS.

A number of Key Performance Indicators (KPI’s) shall be identified, reviewed and results communicated in order to demonstrate continual improvement initiatives regarding environmental impact. This policy statement and objectives shall be regularly reviewed for suitability and updated by the management team, as and when considered necessary.

Primary environmental targets and objectives, as appropriate to the nature of our business, are as follows.

To maintain ISO 14001 certification

To reduce the level of general waste

Participate in the recycling of company generated waste

Increase the use of recycled products and materials

Reduce energy consumption

Prevent any form of environmental pollution within the control of our business operations

Signed

-----------------------------------------------------------------------------------

Tony Thompson Date: 5th September 2012


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Managing Director Distribution: All employees /company website/interested parties


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4.3 Planning

4.3.1 Environmental Aspects and Impacts

Aspects

1. The Environmental Team are responsible for the review, on an annual basis, of the environmental aspects and impacts of the company’s activities, products and services. Aspects shall be categorised high, medium or low in order to identify levels of significance.

2. This shall be recorded and retained in the Environmental Management System file using template ER003. The scope of this review shall include

Operational processes Maintenance Office activities Transport

Risk assessment

3. A risk assessment of each activity shall be carried out and recorded in the companies aspects and impacts register ER003. High risks shall be identified, eliminated, reduced, and/or controlled. The risk assessment shall take into consideration normal, abnormal and emergency situations. Unless otherwise specified or influenced by planned, new developments or modified activities, products or services, the frequency of risk assessment shall be a minimum of once per 12 months. Risk assessment shall be linked to and take into consideration the aspect review results.

4. Existing environmental, operational and safe working procedures are used to break down the process/activities into component parts. Environmental aspects and impacts are taken into consideration when introducing these procedures.

5. These procedures are listed in TABLE 1 below.

TABLE 1. Operational Control ProceduresDoc. Ref. Description

BP001 Internal audit procedure


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BP002 Incident Reporting & Corrective action

BP003 Preventive action

BP004 Document & records control procedure

BP005 Purchasing procedure

BP006 Human Resources

BP007 Measure, analyse & improve

BP008 Waste Management Procedure

BP009 Environmental code of practice (factory and office)

BP010 Business Continuity Plan (incl. Emergency Preparedness and Response}

BP011 Spillages

BP012 Risk assessment

6. The scope of the risk assessment review includes: Production processes Maintenance Office activities Despatch

7. A risk rating of high must be immediately identified to the EMR or designated available management team representative for review of existing controls, risk acceptance and possible introduction of additional controls.

4.3.2 Legal and other requirements compliance

Applicable legal requirements and updates shall be identified via the EMS representative(s) using an external agency or agencies e.g. Environmental Agency via environment-agency.gov.uk/netregs/legislation and contact with external consultant, BSI website. A


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compliance review shall be undertaken to identify relevant controls are in place or justification for exclusions. This review shall be undertaken at a minimum frequency of once per year and be recorded using the Compliance Register. New legislation shall be added to the Compliance Register and implications, accessed via the Management Review process. Changes to the existing EMS procedures shall be implemented by the EMS representative(s).Applicable legal and other environmental requirements relevant to and taking into consideration of identified environmental aspects are as follows:-

1. Environmental Protection Act 1990 2. Environmental Protection Act 1995 3. Climate Change Levy 4. Clean Air Act 1993 5. Environmental Protection (Duty of Care) Regulations SI 1991/2839 6. Waste Electrical, Electronic Equipment (WEEE) 2005 7. Noise Pollution Act 1989 8. Control of Pollution (oil storage) 2001 SI 29549. Control of Substances Harmful to Health (COSHH) Regulations10. Hazardous Waste (England & Wales) Regulations 200911. Trade Effluent Regulations 1990 12. List of Wastes (England) 200513. The Waste (England & Wales) Regulations 2011 SI 98814. SI 588 Controlled waste regulations 199215. Waste Batteries & Accumulators Regulations 200916. Ozone Depleting Substances (Qualifications) Regulations 2009 SI 216 17. ISO 14001 18. ISO 900119. FGAS Fluorinated greenhouse gases regulations SI 2009/26120. Water Industry Act 1991 Chapter 5621. Water Resources Act 199122. Producer Responsibility (Packaging Waste ) Regulations SI 2007/871 At present there are no other environmental requirements applicable such as:

a) Agreements with public authorities

b) Agreements with customers

c) non-regulatory guidelines


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d) Voluntary codes of practice

e) Voluntary environmental labelling or product stewardship commitments

f) Requirements of trade associations

g) Agreements with community groups

h) Public commitments of the organisation

i) Corporate/company requirements

4.3.3 Objectives, targets and programme(s)

Objectives, targets and improvement programmes shall be identified via the Environmental Team and approved by senior management team members, with responsibilities as follows:

Member Environmental Responsibilities

Managing Director Establishing overall environmental management system direction and policy.

Managing Director, *Quality & Environmental Manager

Developing environmental objectives, targets and programmes

Quality & Environmental Manager

Monitoring EMS performance and its operation

Quality & Environmental Manager

Ensuring compliance with applicable legal and other requirements

Environmental team Promoting continual improvement

Managing Director, Technical Sales Manager

Identifying customers’ expectations and dealing with environmental related enquiries from interested parties.

Managing Director/ Purchasing Manager

Identifying requirements for suppliers


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*HR & Financial Director Developing and maintaining accounting procedures, ensuring EMS procedures and standards are maintained in the Office. Maintenance of appropriate waste disposal records

*Production Supervisor Ensuring EMS procedures and standards are maintained in the production areas

*Paint Shop Supervisor Ensuring EMS procedures and standards are maintained in the paint shop.

Stores & Purchasing Supervisor

Ensuring EMS procedures and standards are maintained in the stores areas. Arranging disposal of waste via licensed carriers and forwarding waste transfer notes to the Office.

All employees Conform to EMS requirements

* Environmental team members

The Quality & Environmental Manager (QEM) is the nominated Environmental Management Representative (EMR). The Managing Director is the nominated deputy for the QEM.

Targets and objectives have been included in the Environmental Management Policy & Objectives Statement. Specific targets and objectives and their performance status shall be incorporated within the Key Performance Indicators Report compiled by the Quality & Environmental Manager/EMR and results communicated, as appropriate.

Please refer to procedure BP007 for more details relating to measurement, analysis and improvement activities.

Typical programme format: Activity: Transportation

Aspect Objectives Targets Programmes Indicators Operational controls

Monitoring & Measurement

CNC Reduction of Reduce P001 Soluble oil Controlled by Barrels


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machining

waste cutting oil

by 5% consumption EMR consumed per month

4.4 Implementation & operation

4.4.1 Resources, roles responsibility and authority

The identification of resource needs to effectively manage the EMS shall be identified during the management review process to ensure that necessary people, training, infrastructure, information systems, equipment, facilities and finance requirements are provided.

The minutes of the management review meeting(s) shall make reference to the above.

The Environmental Team personnel and responsibilities have been allocated as per 4.3.3 table shown in this manual.

4.4.2 Competence, training and awareness

Competence: The Environmental Team shall define the necessary level of competence required for individual EMS responsibilities. Appropriate records shall be maintained by the designated EMR in order to demonstrate the individual’s competency.

EMS awareness and training programmes shall be developed by the nominated EMR(s) using the template below. The programme and its status shall be included within the management review meeting process and continually updated

Training course attendance records and certificates shall be obtained by the nominated EMS representative and retained within the individual’s personnel file.

4.4.3 Communication

Internal communication:-

EMS policy, objectives, targets and new developments shall be communicated to new starters and all existing employees as part of the induction programme.

The Environmental code of conduct shall be communicated to all employees ALM Products Ltd Environmental Policy Manual EM001/

ISS.305/09/20

12



EMS awareness training programme maintained by the EMR

The entire EMS documentation shall be made available, in read only format, to all office employees via accessing the shared drive networked computer system.

External communication:-

The company has decided to adopt the following policy in order to effectively communicate about its environmental policy, aspects to interested external parties.

The current authorised environmental policy and objectives statement shall be included within the company’s official website information. It is the responsibility of the EMR to ensure updates to the EMS policy and objectives statement are communicated to the website controller. EMS information requests from external interested parties shall be forwarded to the EMR / designate in order to provide an appropriate response.

The company has decided not to externally communicate details of significant environmental aspects and impacts. However each case shall be subject to internal review.

4.4.4 Documentation

The EMS documentation is structured via the manual and supporting procedures as defined in the table shown in section 4.3 of this manual

4.4.5 Control of documents

All EMS documentation is held within a secure master library system which is reviewed, updated and controlled by the EMR/designate as per documented procedure BP004

4.4.6 Operational control

Operational controls for the significant environmental aspects and risks of the organisation have been identified and documented in the form of the template shown in page 8 of this manual.


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The EMR is responsible for the maintenance and evaluation of the continual effectiveness of this programme plus the maintenance of associated records, as per company procedure BP004.

4.4.7 Emergency preparedness and response

The company has identified potential emergency situations or accidents that can have a detrimental environmental impact, the associated response, controls and management responsibilities as per procedure BP010.

The procedure and associated controls include, where appropriate, consideration of the following.

a) Accidental emissions to the atmosphere

b) Accidental discharges to water and land

c) Specific environment and ecosystem effects from accidental releases

4.5 Checking

4.5.1 Monitoring and measurementThe identification of monitoring and measurement activities is defined by the top management team, as part of the management review process and documented in the form of a Key Performance Indicators (KPI) report (see 4.3.3 of this manual).

4.5.2 Evaluation of complianceLegal compliance is identified via regular reviews undertaken and recorded by the ER003, as per 4.3.2 of this manual.

A programme of internal audits including QMS and EMS is continually evaluated and records maintained by the nominated EMR /designate.

3rd party certification audits are conducted by a UKAS accredited certification body to evaluate compliance with ISO 14001. Records are maintained by the EMR/designate.

4.5.3 Nonconformity, corrective and preventive action


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An incident report log document RT005 shall be used to record all environmental incidents and details entered into the log including a cross reference to the relevant incident report. This information is reviewed by the EMR who shall instigate an appropriate corrective/preventive action plan.

All details are entered into an Incident Report Log under a unique reference number.

Corrective action is defined as the action necessary to eliminate the root cause of the non-conformance, whereas preventive action is defined as the action necessary to prevent the non-conformance in the first place.

The identification and management of actual and potential nonconformity is defined within BP002 & BP003.

4.5.4 Control of recordsRecords needed to provide evidence of the ongoing operation and effectiveness of the environmental management system is included in procedure BP004.

This procedure also specifies the identification, responsibilities, storage methods, retention time and disposal and control of obsolete documents.

4.5.5 Internal auditAn internal audit programme is maintained by the EMR as per 4.5.2 above. The procedure for ensuring that internal audits are effectively undertaken by independent, competent and qualified auditors is defined in BP001.

Results of internal audits are reviewed by senior management as part of the management review process.

4.6 Management review

Management reviews are attended by the top management team and undertaken at a minimum frequency of every calendar year. The procedure defining this process is documented in BP007.


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Fixed agenda inputs:-

Results of audits, legal compliance checks Communication from external interested parties Environmental performance Extent to which objectives/targets have been met (KPI’s etc) Status of corrective/preventive actions Follow up actions from previous review meetings Changing circumstances Recommendations for improvement

Outputs:-

The system’s suitability, adequacy and effectiveness Changes to physical, human, financial resources Actions related to possible changes to environmental policy, objectives, targets or any

other aspects of the EMS.

Records:-

KPI report

Management review meeting minutes


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