7.0  EMS Training & Awareness

The EMS training program is prepared for all employees and contractors working in the Coulson Group of Companies operations. Training policies aim to identify, provide and track environmental training for all individuals whose work may significantly impact the environment.

Training will be provided to implement and maintain the Environmental Management System (EMS).

7.1  Training Needs Assessment

Job-Specific & Emergency Response

Job-specific and training needs are identified by the specific Operational Managers and Supervisors as well as the Personnel Department or Environment Manager. The training needs assessment will be conducted by the Pesonnel Department or Environment Manager. The training needs assessment will be conducted during orientation for new personnel and annually for all personnel.

EMS & Environmental Awareness Training

EMS training needs are identified by the Environmental Manager in collaboration with mill management. EMS awareness training is to be done annually for all employees and contractors. This training is to be documented and submitted to the EMS database using the Training Record Form.

7.2  Training Delivery

EMS Awareness Training

Coulson Staff, Employees and Contractors
All Coulson Group of Companies staff, employees and contractors will receive annual EMS awareness training. This includes basic EMS orientation and training so that all staff, employees and contractors develop a commitment to Coulson Group of Companies Environmental Policy, objectives and targets. They must also be aware of the potential consequences for not following specified policies and Standard Operating Procedures. This training will be done every year or as new objectives and targets are developed and company wide awareness is warranted.

EMS awareness training will include a review of the significant environmental aspects related to personnel duties and work areas. It will also include a review of emergency and spill response procedures and relevant SOP’s, and will instruct employees on where to find information on the EMS, environmental policy and SOP’s and forms that are relevant to their duties and work areas. This includes reviewing the EMS organizational structures and responsibilities (EMS Section 4.0) to ensure that all personnel understand their role and the information and procedures they are required to understand.
EMS awareness training may be conducted by the Environmental Manager, Operational Managers or Supervisors, and may be done in conjunction with job safety breakdown (JSB) reviews or regular staff meetings such as safety. This training is to be documented and submitted to the EMS database using the Training Record Form.

Company Suppliers of Goods and Services
Company suppliers who are required to enter company job sites to deliver supplies, products or perform a service are required to complete in advance the Coulson Group of Company’s basic EMS awareness orientation package consisting of a review of the Company “EMS Policy” and the EMS awareness orientation outline “Simply EMS”. The supplier shall on the form provided, confirm by return mail that they have reviewed both the EMS policy and EMS Awareness outline and that they agree to comply with the policy when on Coulson job sites and properties. Suppliers will be required to complete the awareness package when they are initially engaged to supply the goods or services and will be expected to complete an EMS Awareness refresher every 3 years. The EMS Manager in consultation with the Division manager shall be responsible for ensuring that suppliers receive required EMS orientation.

Job-related Training

Personnel performing tasks that can cause significant environmental impacts must be competent. Competency can be determined on the basis of education, experience, and/or training. Each department is responsible to make sure that personnel are adequately trained for their job function. This will include all related SOPís and relevant Job safety Breakdown (JSB). The Manufacturing Managers and Supervisors are to oversee training.

All personnel must understand the SOP's that relate to their duties and work areas. Relevant SOP’s are to be reviewed during personnel orientation and annually thereafter. This training is to be documented and submitted to the EMS database using the Training Record Form.

All personnel are to have appropriate Workplace Hazardous Materials Information System, or WHMIS Training. WHMIS training needs are to be determined by Operations Managers, and is to be completed during orientation and then periodically as deemed necessary by Operations Managers. This training is to be documented and submitted to the EMS database using the Training Record Form.

Emergency Response Training

Emergency response training requirements are based on the needs and the associated environmental hazards of each operation. Training needs relating to significant environmental aspects including spill and fire response are to be determined by the Environment Manager in consultation with the Operations Manager.
Emergency spill response and fire response training is to be conducted annually for those personnel who are deemed to require such training. This training is to be documented and submitted to the EMS database using the Training Record Form.

Training Records

All training related to significant environmental aspects and the EMS is to be documented and submitted to the EMS database using the Training Record Form. Where training records are recorded in hard copy they are to be submitted to the EMS Clerk who is responsible for maintaining hard copy EMS files and for entering the training records into the EMS database before filing.