Legal register preparation for EHS

Legal register preparation related to Environment Health Safety

Legal register : A document/ form which that list down of legislation, regulations which is applicable to our organization operation.

Why we required legal register ?

It is not mandatory for a company to have a legal register but tracking their compliance again various rules and regulation will be very difficult. Moreover it will be very helpful if we create, we can identify the exact requirements (includes new requirements).

How to create a legal register :

For creating a legal register we need to look at various aspects which are explained below as follows

Note : I have taken India (State- Tamil Nadu) as an example

·       Generally for any industries at India certain basic act/laws are applicable which are as follows

Ø  Industrial safety and health act and rules

Ø  TN Contract Labour (Regulation & Abolition Rules - 1975)

Ø  Tamil Nadu Fire Service Act & Rules

·       List down the manufacturing process carried out by your organizations  - Analysis if any special requirement.

Example :           Boiler                  -             Boiler act is applicable

                             Gas cylinder       -             For gas cylinders

·       List down the chemicals used in the industry, check whether any hazardous chemical you are going to use which requires permission for storage

Example :           Manufacture, Storage and Import of Hazardous Chemicals Rules 1989

                             Petroleum act & rules for petroleum product

                             ARMS Act, 1959 for sulphur

                             Medicinal & Toilet preparation Rules, 1956

                            

·       Check whether any special requirement is applicable for producing your product.

Example :                   Food industry                 - Food Safety and Standard act is applicable

Cosmetics industry         - Drugs & cosmetics act is applicable

·       Check the environment rules & regulation applicable to your factory

Example :          

Hazardous and Other Wastes  Rules, 2016            - If we are generating hazardous waste

Water (Prevention & control of pollution) act, 1974

Air (Prevention & control of pollution) act, 1981

Plastic waste management rules, 2016                  - If we are producer of plastic /brand owner.

Bio-medical waste management rules, 2016        - If we are generating Bio medical waste

E-waste (management) rules, 2016                       

How to create a health legal register :

            A committee to be formed & It should have cross functional team members (Finance, Quality, HR, Engineering etc). Need to be driven by top management.

 

Periodicity for reviewing a legal register :

Frequency of reviewing – Monthly once.

How to get the updates if any change made by enforcement body :

Ø  We should frequently visit the sites of concerned enforcement authorities (at least once in 6 month)

Ø  Becoming a member of professional (local) bodies/ peoples like national safety council, Industrial waste management association etc.       

What can be the plan after implementation of legal register :

    Manual legal register maintained in a excel will consume lot of our time for tracking and maintenance. To avoid this we can create a mechanism for automating it (for follow-up, status collection etc).

WASTE MANAGEMENT HIERARCHY

                                        WASTE MANAGEMENT HIERARCHY 

Definition of waste and hazardous waste : 

• Waste is a product which is no longer suitable for its intended use.

• Hazardous waste is a waste which has potential to cause harmful effect on human health or the environment.

 4R concept can be followed in any waste generation areas which can reduce your waste generation level substantially (both in industry & society). 4R are as follows

    1. Reduce : 

                        Reduce means reducing the waste generation at source itself.

Examples are use drying methods like paddle dryer, solar sludge dryer to reduce the industrial sludge moister consent which can reduce the sludge generation.

    2. Re-use : 

                        Check the possibility of re-using of the generated waste in the same application or some other application.

Examples are use of steel tea cups in place of paper cups, Use of copper bottles instead of one time usage water bottles, Usage of bags (Cloth etc) instead of plastic bags, re-using of chemical cans in Waste treatment plants, effluent treatment plants etc

    3. Recycle : 

                        Always try to use materials which are possible to recycle. Eliminate single usage plastic/material. Recycling a waste may not be possible at our end, so select vendor who has capable to carryout this and dispose it accordingly.

Examples are use of plastics/paper packing instead of single usage plastic.

    4. Recovery : 

                        If the above 3 options are not possible, we can go for recovering energy form the waste.

Example are Check/analysis the characteristics of the materials. Based on the result, if the result has high calorific value the same waste can be used as an alternate fuel in cement industry instead of coal. Which can reduce the consumption of our natural resource.

Always try to follow the 4R concept on waste management. Try to avoid dumping in land, it is major source of contamination and pollution. Dumping in land will affect our eco system very badly. Let us unit for creation of safe environment for our next generation.

Check the above said points and comment if any point got missed out. Please feel free to comment.

How to get sanitary certificate from health department in Tamil Nadu

Sanitary certificate will be issued by our health department. Check with your local health inspector whether it is applicable to your industry/institution. 

Procedure for getting the sanitary certificate are as follow

1. Speak to your local health inspector for getting information related to filling challan (head of account, Data processing code, amount to be paid)

2. Visit tahsildar office - Treasury block/department at your Location to get challan

3. Fill the challan with the details provided by your local health inspector and make Payment in the bank and get a challan copy.

4. Prepare Covering letter mentioning the requirement and challan details. Also mention about the supporting documents which your are planning to attach along with covering letter. Normally the below mentioned attachments will be submitted along with the covering letter

a.       Approved hp and layout details from health department

b.       NOC from fire department

c.       Air & water consent issued by pollution control board

d.       Hazardous waste authorization issued by pollution control board

e.       Factory license issued by inspector of factories

f.        Challan copy

      5. Submit the application to Director/Deputy director of public health & preventive medicines (Always it is better to check with your local health inspector before addressing to the government officials)

      6. Based on your application representatives from health department may come & visit your premises.   

      7. If there is no observation/query, you will get sanitization certificate within few working days

Note : Validity of this sanitary certificate will be one year from the date of issue. You need to renew the certificate before expiry and follow the above said process for renewal also (Include a copy of  previous sanitization certificate as an attachment)

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