Ref Form B2- Summary of Duvelco Limited's Management.Pdf
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Ref: FB2-Q3D Form B2, Question 3D - Summary of Duvelco Limited’s Management System Duvelco Limited was incorporated on 23rd January 2020. Due to the nature of the work that Duvelco Limited intend to undertake and in line with the requirements of a bespoke environmental permit, the company will develop a written management system. This is a set of procedures which describe what the company does to minimise the risk of pollution from the activities it will undertake. Company Profile Duvelco Limited is part of the Goodwin Group. Its parent company is Goodwin PLC and it is one of ten UK subsidiary companies, in a wider global group of 24 companies. Within the group of companies, we have three UK subsidiaries that are accredited to ISO 14001:2015, with a further two working towards stage 2 of accreditation, which is planned for March 2020. At the company’s disposal, there is 7 QHSE Managers, as well as a HSE group manager. In total, our qualified team members have in excess of 100 years’ experience in environmental matters. The range of environmental management qualifications across our qualified team includes: 50001 lead auditor; ESOS lead assessor; 14001 internal and lead auditors; CIEH environmental management training; NEBOSH qualifications in a number of disciplines; Annual legislation update training; Chartered Institute of water and environmental management training; Identification of root cause and corrective action training; Practical management of the environment; Approach to problem solving. Our team also has a number of health and safety qualifications that complement this skillset. We will draw from our group experience to create our management system, which will be in place by the time the company begins any commercial operations, as per permit requirements. Our management team will create a set of procedures which describe what the company will do to minimise the risk of pollution from the activities which will be covered by the company’s bespoke permit. The company’s risks have been identified as part of our risk assessment, which has been submitted as part of our permit application. The company’s management system will use this risk assessment as a basis to create its framework. The company is committed to maintaining a management system which will meet the requirements of ISO14001:2015, as well as other standards and other client specific management systems / processes needed to achieve its long term vision. Scope of Environmental Management System (EMS) The company’s scope is as follows: ‘Development and manufacture of high temperature performing polyimide- based polymers for use in highly demanding and critical applications’. Duvelco Limited is a highly specialised manufacturer, operating in a very narrow market segment of the polymer industry. It is focused on the manufacture and development of the highest temperature performing polyimide based polymers, for highly demanding and critical applications. Polymer resins produced by Duvelco Limited may be supplied as a basic resin for others to mold, or as finished components. Organisation The company’s proposed organisation structure related to environmental management can be seen in Figure 1. Fig 1: Duvelco Limited’s proposed management structure. The success of an environmental management system depends on commitment from all levels and functions of an organisation, led by top management. Top management will effectively address risks and opportunities by integrating environmental management into the company’s business processes. Roles and Responsibilities Top Management – responsible for: Demonstrating leadership and commitment with respect to the environment management system. Endorsing the environmental policy; Ensuring appropriate resource allocation to enable the effective operation and continual improvement of the EMS; Creation of company strategy; Supporting relevant management roles. Environmental Management Representative (EMR) – has the responsibility and authority for: Ensuring that EMS requirements are established, implemented and maintained in accordance with ISO 14001, as well as legislation, legal regulations and Local Authority (LA) rules; Advising top management and the workforce about legal requirements; Ensuring that sufficient resources are allocated for the proper implementation of the environmental policy and the EMS; Regularly reviewing the effectiveness of the EMS and ensuring that the necessary changes are made; Leading the EMS committee to establish and implement the EMS according to ISO 14001 and monitoring the system’s performance; Coordinating internal EMS audits to ensure the EMS has been properly implemented and maintained; Leading and investigating nonconformities and root causes and ensuring corrective and preventive action have been taken to mitigate any impacts that have been caused; Leading the investigations into accidents, incidents and near misses (AINMS); Reporting to top management on the performance of the EMS; Ensuring resources are planned and made available to support the EMS; Ensuring that employees have the correct resources/training to perform their roles; Liaising with any external bodies, e.g. the Environmental Agency (EA) and creation of any required reports/information; Chairing the Environmental committee. Environmental Management System Committee (EMS Committee) – responsible for: Supporting the establishment and implementation of the EMS; Supporting the review of objectives, targets and initiatives; Ensuring the effective implementation of environmentally-related operational controls and programmes; The internal communication of environmental matters between management and employees and promoting environmental awareness amongst staff; Reviewing of documents and records related to the EMS; Supporting the EMR in investigating nonconformities and root causes. Function/departmental manager – responsible for: Performing operational controls for the identified significant environmental aspects for his/her function team/department according to procedures and instructions; Ensuring that the EMS is properly implemented and that environmental matters are properly handled at all stages. All employees – responsible for: Working in accordance with the documented environmental procedures and instructions, specifics responsibilities defined in individual procedures and instructions; Reporting problems or deviations associated with environmental issues and the EMS to the EMS committee. Environmental Management System Requirements The EMS of Duvelco Limited will be developed to manage significant environmental aspects to limit their impacts on the environment. The EMS will be established in accordance with ISO 14001:2015, which we intend to be accredited to within 12 months. Having had experience of implementing ISO 14001:2015 at other group sites in less time, we are confident in this 12 month timescale for accreditation. The EMS shall consist of a manual, which will outline the activities undertaken by Duvelco Limited. From this, a number of procedures will be created to define the processes of the management system, including operational control. A series of forms, spreadsheets and data collection activities will be used to monitor the performance of the system. Internal audits will be conducted to establish the effectiveness of the company’s processes. Environmental Management System Documents The purpose of these EMS documents will be as follows: Site Infrastructure Plan – A plan of the site is included, which highlights where activities are performed, which are covered by the permit, as well as vulnerable locations, drainage, water, gas and electricity. Environmental Policy – Describes the intention and principles to be adopted in relation to environmental performance, including but not limited to legal compliance, continual improvements and pollution prevention. Environmental Management System Manual (EMS Manual) – Describes the environmental management system and outlines how the requirements of the ISO 14001 are achieved. Objective(s) – The overall environment goals that Duvelco Limited set to achieve. Target(s) – The set of measurable performance requirements that Duvelco Limited establishes to achieve the objectives. Environmental Procedures (EPs) – Define the roles, responsibilities and actions to be taken to ensure that activities are performed and the EMS implemented in accordance with the environmental policy and the requirements of ISO 14001. Register of Environmental Aspects and Impacts – Compiles the environmental aspects that are derived from the activities and services of Duvelco Limited. The register also denotes the significance of the environmental aspects and the respective operational controls for significant environmental aspects. Register of Legal and Other Requirements – Compiles the legal and other requirements, which include legislation, codes of practice, regulatory and non-regulatory guidelines that are applicable to Duvelco Limited. Environmental Forms/Records – Record information for the audit trail and the assessment of environmental conditions and performance. EMS Procedures Below is a table of Duvelco’s EMS procedures which will be developed by our group’s environmentally-focused management team. We have also listed the applicable clause of ISO14001:2015, which will be covered by the new procedures. ISO Procedure Document 14001:2015 Type Clause 4.1, 4.2, 4.3, Environmental Manual – context of the organisation, Manual 4.4, 5.1, 6.1.4, needs and