SHEC CORPORATE MANAGEMENT SYSTEM STANDARD

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1 SHEC CORPORATE MANAGEMENT SYSTEM STANDARD NONCONFORMANCE, CORRECTIVE AND PREVENTIVE Doc No: 6.2. NONCONF. 1 Copy No: Issued to: Approval: Mitch Jakeman Issue Issue Date Originator Reviewed Approved 3 13 TH December 2004 MO/FF MO/FF/MJ M Jakeman 2 11 th September 2003 DT DTMJ D Taylor 1 DT/JC/MO/FF DT/JC D Taylor Note: Only controlled copies receive updates

2 Standard Overview ACApl SHE Management System Model Nonconformance, Corrective and Preventive Action Auditing Management Rev iew Leadership & Commitment CONTINUAL IMPROVEMENT Policy Planning Identification and management of nonconformances - Incident reports - Complaints - Internal and external audits - Hazard and housekeeping inspections - Monitoring and measuring - General observation Corrective, Preventive and Actions (CPAR) Monitoring & Evaluation Risk Management Implementation Key Responsibilities - Employees - Supervisors - SHEC focal points - s - Auditors - Site GMs Timing : Ongoing Page 2 of 13

3 Amendments Issue Date: Description Initi al 1 Issue DT 2 11 th September th December 2004 Amended Advisory List Deletion of pre SiteSafe / Impact methods for managing nonconformances etc Minor wording changes DT MJ Distribution List COPY No. 1. Distributed To: General, SHECTRA, Anglo Coal Australia Page 3 of 13

4 Advisory List Chief Executive Officer, Anglo Coal Australia General Open Cut Operations, Anglo Coal Australia General Underground Operations, Anglo Coal Australia General, Callide Mine General, Dartbrook Mine General, German Creek Mine General, Drayton Mine General, Moranbah North Mine General, Moura Mine Corporate Risk, Anglo Coal Australia Environmental Coordinator, Anglo Coal Australia Safety & Health Coordinator, Anglo Coal Australia Technical Services, Callide Mine Senior Environmental Adviser, Callide Mine Safety & Health, Callide Mine Technical Services, German Creek Mine Senior Environmental Adviser, German Creek Mine Environmental Adviser, German Creek Mine Safety & Health, German Creek Mine Grasstree Safety Training Officer Technical Services, Dartbrook Mine S&H, Dartbrook Mine Senior Environmental Coordinator, Dartbrook Mine SHEC, Drayton Mine Technical Services, Moranbah North Mine Environmental Adviser, Moranbah North Mine S&H, Moranbah North Mine Technical Services, Moura Mine Environmental Adviser, Moura Mine Safety & Training, Moura Mine Executive Officer Growth & Business Strategy, Anglo Coal Australia Chief Financial Officer, Anglo Coal Australia General, Projects, Resources & Business Development, Anglo Coal Australia Project, Grasstree Development Project, Dawson Valley Project, Lake Lindsay Resource, Anglo Coal Australia Page 4 of 13

5 NONCONFORMANCE, CORRECTIVE AND PREVENTIVE 1 Management System Reference This standard forms a major part of the Management System Element Monitoring and Evaluation. 2 Purpose The purpose of this Standard is to provide a consistent framework for defining responsibility and authority for identification, reporting and investigation of incidents and nonconformances. This framework will provide for effective corrective and preventive action to be taken and for all areas of the business to benefit from the knowledge gained. The aim of the nonconformance, corrective and preventive action process is to ensure that the fundamental causes of nonconformances are identified, corrected and prevented in future. 3 Scope This Standard applies to all areas of operation of ACApl, including projects and corporate office. 4 Definitions Nonconformance: Any outcome that is contrary to planned requirements or non-fulfillment of a specified requirement of the management system including, but not limited to, Management System Standards, legislation, licenses, and obligations to stakeholders. Immediate Action: (often called remedial action) Action to address the immediate consequence of the deficiency or action to simply redress the effects of the deficiency (e.g. clean up the oil spill). Corrective Action: Action taken to address the fundamental cause of a nonconformance (incident) to prevent recurrence of that or similar type incident in the future, and to ensure that the action was effective (e.g. conduct investigation into fundamental cause of that type of spill and take action to prevent similar occurrences in the future). Preventive Action: Action taken resulting from analysis of relevant data sources, where trends indicate the potential for nonconformance, should the fundamental cause go unresolved. Preventive actions are of a proactive nature: they do not wait for nonconformances to occur, as they prevent occurrence rather than recurrence they cannot, by definition, be taken on an instance of nonconformance as the deficiency has already occurred (e.g. conduct investigation into fundamental cause of ongoing minor spills recorded in the workshop and take action to prevent it becoming a major problem in the future). Page 5 of 13

6 SiteSafe/Impact (SSI): Proprietary software developed by BMS solutions, used by ACApl to record and manage SHEC information Page 6 of 13

7 5 Procedural Requirement 5.1 Identification and Management of Nonconformances Nonconformances requiring Corrective or Preventive Action may be identified in any of the following ways: Incident reports Complaints Internal and external audits Hazard and housekeeping inspections Monitoring and measurement General observation Incident Reports RESPONSIBLE RECORD Reports of incidents will be initiated as a result of adverse occurrences affecting the safety and health of employees, harm to the environment, or breach of stakeholder obligations. Reports may be made via the SSI incident Notification netform or in hard copy format. Incident notification forms (electronic or hard copy) shall be forwarded to the employees direct supervisor. Where action has already been taken to address the deficiency or nonconformance, details shall be noted on the form Where notification is made in hard copy, incident details shall subsequently be entered into SSI. The supervisor shall complete the Incident Details netform and subsequent netforms describing the detail/type of incident. Automatically generated s shall be forwarded to appropriate site personnel including the Environmental or S&H Focal. s to other persons may be generated as deemed necessary depending on the nature and/or extent of the incident.. A preliminary investigation shall be conducted into the causes of the incident and immediate actions required to address the deficiency shall be determined. All incidents shall, at a minimum, require immediate action to address the deficiency or nonconformance however this may have been completed at the time of the incident. Employee Employee / Supervisor Emp[oyee / SSI data entry person Supervisor Supervisor Supervisor Incident Notification Form Hard Copy / s Page 7 of 13

8 RESPONSIBLE RECORD Each incident shall be assessed to determine the need for corrective action (action to prevent recurrence). Where action or further action to address the deficiency is required, the persons responsible for the actions shall be consulted to agree the nature and scope of those actions. Investigation outcomes and details of agreed actions shall be entered into the Investigation and Action netforms. Where the incident has an actual or potential IPM rating greater than 3, the Formal Root Cause Analysis netform shall be completed. Where corrective action is not required the Incident Sign off netform shall be completed. Where corrective action is required, the procedure outlined in item 6 below shall be followed Incidents shall be analysed at least quarterly to identify any developing trends Negative trends shall be addressed by assigning preventive action in accordance with the procedure outlined in item 6 below Senior Supervisor Senior Point As per site sign off process (typically Senior / SHEC focal points / General ) Site SHEC focal points Site SHEC focal points Action Request Quarterly Trend Analysis Complaints RESPONSIBLE RECORD All complaints shall be recorded in the site Communications Register as per Corporate Standard 4.2.COMCON.1 Each complaint shall at a minimum require immediate action to address the complaint Each complaint shall be assessed to determine the requirement for corrective action (action to prevent recurrence). Where corrective action is required the procedure outlined in item 6 below shall be followed Where corrective action is not required, the reason for this decision shall be noted in the Communications Register. Communications Register Communications Register Communications Register Page 8 of 13

9 Complaints recorded in the Communications Register shall be analysed quarterly to identify any developing trends Negative trends shall be addressed by assigning preventive action in accordance with the procedure outlined in item 6 below Quarterly Trend Analysis Internal Audits / External Audits RESPONSIBLE RECORD Internal Audits shall be carried out in accordance with Corporate Standard 7.AUDREV.1 Where corrective action is required the procedure outlined in item 6 below shall be followed Auditor Auditor Audit Records Page 9 of 13

10 5.1.4 Hazard and Housekeeping Inspections RESPONSIBLE RECORD All deficiencies identified during Hazard and Housekeeping inspections shall be recorded in the Hazard Report netform, in either electronic or hard copy medium. Information from hard copies shall subsequently be entered into SSI Each deficiency shall at a minimum require immediate action to address the hazard or housekeeping issue Each deficiency shall be assessed to determine the need for corrective action (action to prevent recurrence) Where corrective action is required the procedure outlined in item 6 below shall be followed All logged deficiencies shall be analysed quarterly to identify any developing trends Negative trends shall be addressed by assigning preventive action in accordance with the procedure outlined in item 6 below Inspector Inspector Site SHEC focal point/s Site SHEC focal point/s Quarterly Trend Analysis Monitoring and Measurement RESPONSIBLE RECORD Sites shall monitor all parameters required under regulatory obligations and site standards. Where monitoring results indicate nonconformance, immediate actions shall be assigned and persons notified in accordance with regulatory requirements Each non conformance shall be recorded as an incident and assessed to determine the need for corrective action (action to prevent recurrence) Where corrective action is not required (because immediate corrective action was effective), complete the SSI Incident Report Where corrective action is required the procedure outlined in item 6 below shall be followed Monitoring and measurement shall be analysed quarterly to identify any developing trends SHEC personnel and others who are formally assigned monitoring and measurement tasks Site SHEC focal point Site SSI Incident Report Site SSI Incident Report Site SSI Incident Report Quarterly analysis report/s Page 10 of 13

11 Negative trends shall be addressed by assigning preventive action in accordance with the procedure outlined in item 6 below Site SHEC focal point Page 11 of 13

12 5.1.6 General Observation RESPONSIBLE RECORD All general observations shall be recorded in the Minor Hazard / Report record and immediate action shall be taken to address the deficiency Each deficiency shall be assessed to determine the need for corrective action (action to prevent recurrence) Observer Where corrective action is not required complete the Minor Hazard / report Where corrective action is required the procedure outlined in item 6 below shall be followed Minor Hazard / Report Minor Hazard / Report Minor Hazard / Report 6. Corrective, Preventive and Action RESPONSIBLE RECORD Once the need for Action has been determined (see above) the (CPAR) netform in the appropriate section of SSI shall be completed The CPAR shall be ed to the person / supervisor / manager responsible for the activity requesting them to: accept the CPAR and ensure that it is appropriate, the wording is accurate and the action is Specific, Measurable, Achievable, Realistic and Time-bound worded identify the action/s that shall be taken to address the deficiency with start and completion dates An investigation shall be completed to determine the fundamental causes of the deficiency and identify any corrective or improvement actions required to prevent recurrence of the deficiency or to achieve improvement Action taken to address deficiencies or improvements shall be recorded on the CPAR, including the results of the investigation, proposed corrective / preventive action and proposed start and completion dates The status of CPARs shall monitored on a monthly basis to ensure that actions are closed out by agreed completion dates. Person identifying discrepancy Person identifying discrepancy Person receiving CPIAR Person receiving CPIAR Responsible General SSI CPIAR status reports Page 12 of 13

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