4.3 Handling Environmental Non-conformance

This section defines how environmental non-conformities and the resulting corrective and/or preventive actions are to be handled.

Procedures for handling environmental non-conformities are reviewed by the Senior Management Team. The team determines whether the appropriate action was taken for each non-conformance.

All completed investigations forms, inspection reports, incident reports, spill reports, and related EMS forms are confidential and for internal use only.  Release of EMS and related forms, reports, correspondence, monitoring data or meeting minutes must have the consent of Coulson’s Legal Counsel.

All employees are responsible to identify, correct if possible, and report environmental non-conformances. Reports can be made to the appropriate supervisor who in turn must inform the following personnel:

·         the Environment Manager

·         the Directors of Maintenance

·         the Quality Assurance Manager

Types of non-conformance

A non-conformance can be identified through any one of the following:

·         Audits

·         Routine monitoring and inspection

·         Environmental incidents

·         Government agency compliance inspections

·         Communications or complaints from the public.

Types of non-conformities and the appropriate action for each are as follows:

Non-conformance resulting from an Audit

All non-conformities identified through internal audits are required to be documented in the audit report. The Environment Manager is responsible for preparing a corrective action plan, listing each of the non-conformances identified. The corrective action plan is to be completed in consultation with the General Manager and / or those managers responsible for the areas and operations for which non-conformances have been identified. The corrective action report must include the following information for each non-conformance:

§         the non-conformance

§         corrective action required

§         any special equipment, services or resources required, where applicable

§         the person responsible for completing the corrective action

§         the date by which the corrective action is to be completed.

 

The Environment Manager is to provide the completed corrective action reports to the annual EMS Management Review and summarize the status of corrective action measures, the success of these and any resulting changes to operations, management or procedures.

Non-conformance resulting from measuring, monitoring or EMS use

Managers and supervisors should record all reasonable reports of non-conformities raised by Coulson staff, employees or contractors, using the EMS inspection report. The responsible Manager in collaboration with the Environment Manager will decide the action required to remedy the problem.

If the non-conformance is considered minor and sufficient corrective action has taken place, the non-conformance is recorded in the comments section of the EMS inspection record.

If the non-conformance requires additional follow up an Environmental Incident Investigation form must be completed outlining remediation required and who will complete the work. A copy of the report must be forwarded to the appropriate operations manager and the Environment Manager.

The General Manager and Chief Operating Officer must approve corrective action plans when the cost is considered a capital cost.

Non-conformance resulting from environmental incidents

Whenever an incident occurs that relates to a significant environmental aspect it is to be documented and submitted to the EMS database using an Environmental Incident Investigation Form. Such incidents may include a chemical, fuel or lubricant spill, a failure to contain wastes, fire, or any pollutant release. All investigations are recorded and tracked by the relevant Manager. If the investigations relate to a potentially hazardous spill, a Aviation Spill Report Form must also be completed. Once completed, the Environmental Incident Investigation Form and corrective action plan is sent to the Environment Manager for Management Team review and approval.

Evaluation and follow-up of a Corrective/Preventive Action

Once a non-conformance has been identified and documented and submitted to the EMS database using an Environmental Incident Investigation Form, the operation must track the response to the issue using a corrective action plan.

In order to prescribe an efficient corrective action, every effort must be made to identify the root cause and prescribe necessary changes to procedures to ensure the non-conformance will not reoccur.

After implementing the corrective action, the responsible Manager must complete a follow up Environmental Incident Investigation Form for review by the Management Team to ensure that the corrective action was efficient in eliminating the problem and effective to prevent a future re-occurrence.

The Environment Manager will prepare a summary report of non-conformance issues for review by the Management Team at the annual Senior Management Team meeting.

Non-conformance requiring document, form or procedure changes

Should a corrective action require document, form or procedure changes, the Operations Manager responsible for the activity shall provide the suggested corrections (in writing) to the Environment Manager who in turn will coordinate and issue the necessary amendments.