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).