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TATA Realty

(Tata Housing Development Company Limited)


Project Management Group

SOP for Managing OHS Hazards, Env Aspects, Risks and


Opportunities
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-002, Rev No: R1

TATA Realty
Name Designation Signature Date

Prepared By Devesh Ghuley CO DGM- EHS 10-01-2022


Reviewed and 10-01-2022
Virendra Singh CO AVP- EHS
Recommended By
Head – QAQC 10-01-2022
Approved By Vijayakumar
& EHS

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-002, Rev No: R1

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Disclaimer

Issued as: CONTROLLED COPY / UNCONTROLLED COPY for information purpose (Appropriate status
to be highlighted) this document is the property of and Tata Realty (TRIL & Tata Housing) and their
subsidiaries. Print out of this plan shall be uncontrolled copy unless its controlled/ master copy seal.
Unauthorized photocopy or electronic copy either partly or fully is prohibited. Authorized controlled
copy of this document is available at Corporate EHS Team and shall be issued by them.

Revision History

Section Ref in
S. N which changes Description of revisions done Rev. No
carried out
1 NA Original Issue R1

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-002, Rev No: R1

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SOP for Managing EHS Hazards, Aspects, Risks and Opportunities

Reference:

Clause Title ISO Section Reference


Planning (Title only) 6
Actions to Address Risks And Opportunities (Title only) 6.1
General 6.1.1
OHS hazards and Environmental aspects (Title only) 6.1.2
Hazard Identification, assessment of risks & opportunities
6.1.2, 6.1.2.1, 6.1.2.2 (ISO 45001)
and determining Controls (HIRAC)
Environmental aspects, Impact Assessment and Control
6.1.2 (ISO14001)
(EIAC)

Planning

1 Action to address risks and opportunities

1.1 General
Organisation has established, implemented and maintained process (es) needed to meet the
requirements of EHS risks and opportunities, HIRAC & EIAC, legal and other requirements (compliance
obligation), planning action with effective participation of workmen and/ or their representatives.
When planning for the EHS MS, organisation has considered:
1. internal and external issues referred to chapter 4.1 of EHS Manual (context of the organization),
2. requirements of need and expectation of workers and other interested parties referred to
chapter 4.2 of EHS Manual
3. the scope of its EHS MS referred to chapter 4.3 of EHS Manual
And determining the risks and opportunities, relates to HIRAC, EIAC, compliance obligation and other
issues (internal and external) and requirements (need and expectation of workers and other interested
parties) that needs to be addressed to:
1. give assurance that EHS MS can achieve its intended outcome(s);
2. prevent, or reduce undesired effects, including the potential for external environmental conditions to
affect the organisation;
3. achieve continual improvement.

Workers and/ or their representatives and, where appropriate, other interested parties shall effectively
participate in planning process of EHS MS.
When determining risks and opportunities shall be addressed, Organisation shall take into account
followings that can affect the achievement of the intended outcomes.

S. No. Key elements Refer Documented information Template


OH&S risks related to hazards TMT – 004
1 SOP-002
and OH& S opportunities
2 Environmental aspects SOP-002 TMT – 004
Compliance obligations/
3 applicable legal and other SOP-003 TMT – 006
requirements

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S. No. Key elements Refer Documented information Form
4 Internal and external issues EHS Manual - chapter 4.1 TMT – 002
Internal and external
5 EHS Manual - chapter 4.2 TMT – 002
interested parties
Potential emergency
6 SOP – 002 & SOP - 009 TMT – 002
situation *
Other, if any
Risks and opportunities
related to the
7 establishment, SOP – 009 TMT – 002
implementation, operation
and maintenance of the EHS
MS
Note: * Within the scope of the EHS MS, organisation shall determine potential emergency situations,
including those that can have an EHS impact/ risks.
The organization, in its planning process (es), has determined and assessed the risks and opportunities
that are relevant to the intended outcomes of the EHS management system associated with changes in
the organization, its processes or the EHS management system. In the case of planned changes,
permanent or temporary, this assessment shall be undertaken before the change is implemented.

Risk assessment:
 Risk associated with above mentioned aspects are calculated based on Severity of Impacts and
probability.
 Determine Risk Assessment & Opportunity before control measures
a. Risk Value = Severity X Probability;
b. Risk Value: 15-25: H (High Risk Level); 8-12: M (Medium Risk Level); 1-6: L (Low Risk Level)
c. Criteria for High Risk Condition (for risk without control measures):
At least any one condition applicable:-
Risk Value: 15-25 OR Legal: Applicable OR Emergency: Applicable.
Beside this, opportunities are also identified as per applicability. Controlling/ improvement
measures are addressed.
High risk shall be always under control and monitored closely. Aspects associated with
opportunities may be improved by improvement measures/ objectives.
For risk assessment (risk matrix, probability scale and severity scale details), please refer chapter HIRAC
of this document.

Doc. Ref: Template TMT – 002, TMT – 004 and TMT - 006

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Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-002, Rev No: R1

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1.2 OHS hazards and Environmental aspects
1.2.1 Hazard Identification, assessment of risks & opportunities and determining Controls (HIRAC)

Purpose: The overall purpose of this process is to understand the hazards that might arise in the course
of routine/ non-routine activities and ensure that the risks to people arising from these hazards are
identified, assessed, prioritized, controlled and monitored to a level that is acceptable.
Scope: All Project sites and offices of organisation and its subsidiaries;
Responsibility and authority: Department/ Functional Head/ Project Head/ Manager shall be
responsible for HIRAC preparation and implementation of necessary control measures in their area of
responsibility:
When to prepare HIRAC:
 Before execution of any work, plant or equipment.

 Before significantly changing a work practice or procedure.

 Before changing any activity or process, where the change may give rise to a risk to health or safety.

 For managing risk arising out of changes in the inputs, process, technology regulatory regime etc.

Expectations from Hazard Identification, Risk Assessment & Management (As per Tata Group Safety
and Health Manual: Element 2):
Risk Assessment & Management is a continuous process and the bedrock of Safety & Health and hazard
identification is the starting point for effective risk management process. It is essential to anticipate and
identify the hazards that can cause harm to people, damage to property, equipment, environment, or a
combination of these due to our operations. Appropriate action is required to be taken to evaluate and
control these risks on the principles of hierarchy of controls. Risk assessment is to be done on a periodic
basis and actions taken to maintain the risk under control.
Expectations:
2.1. A system is in place to ensure a comprehensive hazard identification process. The system must
consider normal, abnormal and potential emergency situations. A written procedure is in place for the
ongoing identification of hazards.
2.2. Potential hazards and risks to personnel, facilities, the public, customers and the environment are
assessed for existing operations, products, business developments, acquisitions, modifications, new
projects, closures, divestments and decommissioning.
2.3. The hazard identification process is undertaken by a team of competent persons and involving the
workforce and / or its representatives. A hazard profile exists in the organisation’s document control
system. The review process considers the output of other element review processes and past impacts to
business.
2.4. Hazard identification systems exist from a top-down approach via strategic management
assessments and a bottom-up approach by front line people. High hazards are communicated to senior
leaders based on
the hazard profile.
2.5. As a minimum, identified high hazard installations are prioritised during the process of creating risk
control systems. A written procedure is in place to set out the ongoing risk assessment and control in
order to reduce safety & health risks to levels as low as is reasonably practicable.
2.6. Risk assessments are sufficient in relation to the nature and scope of the identified hazard. They are
documented within the management system and are subject to review. Review periods are proportional
to the scope and complexity of the risk.
2.7. The type of risk assessment techniques are used in proportion to the hazard profile and industry.
Written procedures are in place describing the application of risk assessment techniques.

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2.8. Assessments are undertaken by competent people and take into account specific legal requirements
and mandatory company standards. Specialists are appointed to oversee the risk assessment process for
identified high hazard facilities.
2.9. Risk control strategy follows established control hierarchy and aims first to eliminate the hazard and
then seeks to reduce the potential consequence(s) or exposure frequency through the implementation
of risk control systems.
2.10. Assessed risks are reviewed and addressed by levels of management appropriate to the nature and
magnitude of the risk. Decisions are clearly documented and resulting actions
implemented through local procedures.
2.11. Identified safe systems of work are owned by members of line management and are subject to
periodic review. Clearly written management procedures exist to ensure the effective application of the
risk control system.
2.12. Clearly defined communication lines exist to ensure that all relevant people who may be affected
by the risk receive appropriate training and instruction resulting from the risk assessment. Follow-up
systems are in place to ensure decisions taken as a result of risk assessments are communicated to all
relevant people.
2.13. Identified high hazard facilities undertake task analysis to ensure human factors are effectively
managed. An appropriate prioritisation methodology based on risk and the degree of man-machine
interface is used.
2.14. Risk assessments are updated at specified intervals including after changes, and on an occurrence
incident. In certain cases such as construction activities, risk assessments must be done more frequently.
2.15. Systematic reviews are undertaken to ensure that risk control systems are in place to manage the
risk from hazards and aspects identified.

Process Flow Chart

Figure 1.2.1.A

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Process description
HIRAC shall be prepared by Department / Functional Head / Project Head/ Manager or their delegated
line function staff including contractor’s staff at planning stage to eliminate, reduce or isolate the
potential hazards as well as to proactively organize resources before activity commence.
Project head shall form a HIRAC team that comprises of Department / Functional Head / Project Head/
Manager or their delegated line function staff including contractor’s staff to prepare the HIRAC.
Participation of relevant multiple stakeholder (workmen/ workmen’s representatives/ contractor/
supplier/ external expert/employees, etc.) is must. The team member should be appropriately trained
for conducting HIRAC.
Points to be consider while preparing HIRAC: Legal requirements, activities, product, plant, machinery,
equipment, site conditions, work methodology, previous incidents history, company manual,
procedures, operational control procedures, and change in activity, process, behavioural aspects, etc.
Before initiating HIRAC, method statement with details activities may be considered. In case of all high
risk activities, the method of statement and HIRAC shall be prepared.
In case of petty contractor, method statement and HIRAC shall be submitted by ORGANISATION’s
execution team to ORGANISATION’s EHS team for review.
In case of major contractor, method statement shall be submitted by contractor to client. The submitted
documents shall be jointly reviewed by ORGANISATION’s execution and EHS team.

Steps for HIRAC:


Step 1 Identify the Hazards
Step 2 Decide who might be harmed and how
Step 3 Evaluate risk and decide on precaution & Identification of OH& S Opportunities
Step 4 Record Significant Findings
Step 5 Review assessment and update if necessary

Details of steps of HIRAC:-


Step 1 Identify the Hazards
6.1.2.1.1 Hazard Identification
Organisation has established, implemented and maintained this procedure for the on-going proactive
identification of hazards arising in the workplace, and to workers. This procedure has taken into
account:
a) how work is organized, social factors (including workload, work hours, victimization, harassment and
bullying), leadership and the culture in the organization;
b) routine and non-routine activities and situations, including hazards arising from
1) infrastructure, equipment, materials, substances and the physical conditions of the
workplace;
2) product and service design, research, development, testing, production, assembly,
construction, service delivery, maintenance and disposal;
3) human factors (e.g. Human behaviours, capabilities, human factors)
4) how the work is performed
c) past relevant incidents, internal or external to the organization, including emergencies, and
their causes;
d) potential emergency situations;
e) people, including consideration of:
1) those with access to the workplace and their activities, including workers, contractors,
visitors and other persons;
2) those in the vicinity of the workplace who can be affected by the activities of the
organization;
3) workers at a location not under the direct control of the organization;

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4) Special group of people: pregnant lady, handicapped workmen, less experienced,
lone worker, etc. if any.
f) other issues, including consideration of:
1) the design of work areas, processes, installations, machinery/equipment, operating
procedures and work organization, including their adaptation to the needs and capabilities of
the workers involved;
2) situations occurring in the vicinity of the workplace caused by work-related activities under
the control of the organization;
3) situations not controlled by the organization and occurring in the vicinity of the workplace
that can cause injury and ill health to persons in the workplace;
g) actual or proposed changes in organization, operations, processes, activities and the OH&S
management system;
h) changes in knowledge of, and information about, hazards.
i) past incidents, internal or external to the organization, including emergencies, and their
causes, post emergency event recovery learnings.
j) identified hazards originating outside the workplace capable of adversely affecting the
health and safety of persons under the control of the organization within the workplace;
k) Any applicable legal obligations relating to risk assessment and implementation of
necessary control.
l) Consider consequence of any incident that arising due to activities or product of organisation that can
impact to surroundings including local resident, industry, flora fauna, and structure.
m) Consider consequence of any incident that arising due to activities or product of nearby
organisation that can adverse impact to workplace, workmen and organisation’s activities and product.
n) All the activities, facilities and processes of the organization over which it has direct control
and those over which it can be expected to have an Influence.
o) Audit result (any non-conformance/ observations).
EHS Objectives, Management of change (MOC), learning from incident (safety alert) process is directly
linked with HIRAC. Reference of these may be given in HIRAC record.

Define activity
 Develop a list of process to be undertaken by the department.
 Break this process into a list of major activities & sub-activities.
 Get an updated plan, methodology, list of manpower, materials and equipment to be used for
execution of this activity & sub-activity.

Identify hazards: Every activity of any task has its own hazards & risks. The first step is to identify the
work place hazards in connection to activities, machine, equipment, material, men etc.
Identify and list down the hazards associated with each activity & sub-activity using the appropriate
method such as
- Visual Inspection
- Auditing
- Testing/ monitoring
- Technical or scientific evaluation
- Group exercise
- Discussion with specialist, designers, manufacturers, suppliers, supervisor, workers or other
interested parties.
- Legal requirements
- Check manufacturers' instructions or data sheets for chemicals and equipment as they can be very
helpful in spelling out the hazards and putting them in their true perspective
- Review incident and ill-health records - these often help to identify the less obvious hazards

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- Take account of non-routine operations (e.g. maintenance, cleaning operations or changes
activities etc.)
- Remember to think about long-term hazards to health (e.g. high levels of noise or exposure to
harmful substances)
- Visit the website (for example Health and Safety Executive). HSE publishes practical guidance on
hazards and how to control them
Training on proactively identification of hazard is necessary at site. In which, one of best way to identify
the unsafe act/ conditions existing at sites and conduct a brain storming to understand and realize
potential risks and its control measures.
For detail, Refer OPCP for Hazard Identification.

Following types of hazards shall be proactively identified as per applicability and capability.

3. BIOLOGICAL 1. PHYSICAL
• HAZARDS 2. CHEMICAL & DUST HAZARDS

(Mold, HAZARDS (Noise, moving parts,


insects/pests, insulation damage,
(Cleaning products,
communicable temperature
pesticides, asbestos,
diseases, etc.) extremes, radiation,
etc.)
etc.)

4. PHYSIOLOGICAL/
ERGONOMIC HAZARDS 5. PSYCHO-SOCIAL HAZARDS
(Repetition, lifting, (Stress, Violent at workplace etc.)
awkward postures, etc.)

Figure 1.2.1.B

Step 2 Decide who might be harmed and how


Consider the person who get harmed for example: workmen/ employee/ vendor/ supplier/ public/
contractor or group of people (maintenance/ scaffolder/ welder/ security/ office boy/ mess workers/
photocopier etc.
There are special group of people (e.g. pregnant women, young person/ trainee, old people, disabled,
temporary worker, night/ shift worker, lone workers) are prone to high risk.

Step 3 Evaluate risk and decide on precaution & Identification of OH& S Opportunities
1.2.1.2 Assessment of OH&S risks and other risks to the OH&S management system
Organisation has established, implemented and maintained this procedure to
a) assess OH&S risks from the identified hazards taking into account the effectiveness of existing
controls and considering the hierarchy of controls (Refer chapter 8.1.2);
b) determine and assess the other risks related to the establishment, implementation, operation and
maintenance of the OH&S management system.

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Organisation has defined methodology and criteria for assessment of OH&S risks with respect to their
scope, nature and timing, to ensure they are proactive rather than reactive and are used in a systematic
way.
Risk assessment is an important exercise to determine the level of risk and priorities controlling the
hazards. The higher risk requires more attention, priority to put control, needs more monitoring and
needs multiple controls. Risk assessment is to be carried out for each hazard.
Risk assessment is an important steps to achieve the purpose of Organisation EHS management system
i. e. to achieve safe and healthy working conditions with a level of residual risk which is as low as
reasonably practicable.
Following sub-steps:
A) Evaluate risk
A.1) Identify Likelihood (P) in number as per defined table.
A.2) Identify consequence/ severity (S) in number as per defined table.
A.3) Calculate risk (Risk = Likelihood X Consequence)
A.4) Determine risk level (High risk, medium risk and low risk) as per defined risk matrix.
A.5) Determine whether risk at ALARP level (Acceptable) or not ALARP level
B) Identification of OH& S Opportunities
C) Decide on precaution
A) Evaluate risk
A.1) Identify Likelihood (P) in number as per defined table.
PROBABILITY FACTOR - (P)
P Probability Frequency Ratio
1 Remote 1 in every 10 year of operation. 1:1000
2 Unlikely 1 in every year of operation. 1:100
3 Occasional 1 in every month of operation. 1:10
4 Likely 1 in every week of operation. 1:4
5 Frequent 1 in every day of operation. 1:2

A.2) Identify consequence/ severity (S) in number as per following defined table.
SEVERITY FACTOR - (S)
S Severity Impact
Slight injury or health effects (including first aid and medical
1 Negligible treatment cases) not affecting work performance or causing
disability.
Minor injury or health effects-affecting work performance e.g.
restriction to activities or need a time off to recover (Lost time
2 Marginal
accident) reversible health effects, e.g. eye/ skin irritation, food
poisoning, back ache or body ache.
Major injury or health effects (including permanent disability) –
affecting work performance in longer term, e.g. irreversible health
3 Critical
damage without loss of life (Noise induced hearing loss, chronic back
injuries)
Single fatality or permanent total disability or major occupational
4 Severe
illness/ sickness.
Multiple fatalities from an incident or Occupational chronic illness
5 Catastrophic
leading to death/ fatality (poisoning, dengue, malaria).

A.3) Calculate risk (Risk = Likelihood X Consequence)


Risk Level = Severity (S) X Probability (P)

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A.4) Determine risk level (High risk, medium risk and low risk) as per following defined risk matrix.
PROBABILI 5 5 L 10 M 15 H 20 H 25 H
TY 4 4 L 8 M 12 M 16M 20 H
3 3 L 6 L 9M 12 M 15 H
2 2 L 4 L 6 L 8M 10 M
1 1L 2L 3 L 4 L 5 L
1 2 3 4 5
SEVERITY
Risk Slab Risk Level Colour code
From 1-6 Low Risk (L)
Between 8 - 12 Medium Risk (M)
More than 15 - 25 High Risk (H)
Conditions for high risk determination: Following three conditions determine high risk:-
1. When the risk level is 15 to 25 as specified in the risk matrix,
2. When legal requirement is applicable
3. When emergency condition is identified.
The risk shall be determined as high risk if any of the above mentioned condition is applicable.

A.5) Determine whether risk at ALARP level (Acceptable) or not ALARP level (non acceptable) risk
Low risk category is considered as an acceptable risk i.e. as low as reasonably practicable (ALARP) low.
The medium and high risk shall be unacceptable risk/ not considered at ALARP level.
The risk is the outcome of hazards and depends upon the severity of hazard and probability of
occurrence of incident. Each Probability and severity is required to be ranked in 1 to 5 scale to rate their
severity and probability for evaluating the risk level.

B) Identification of OH& S Opportunities


1.2.1.3 Assessment of OH&S opportunities and other opportunities for the OH&S management
system
Organisation has establish this procedure to assess:
a) OH&S opportunities to enhance OH&S performance, while taking into account planned changes to
the organization, its policies, its processes or its activities and:
1) opportunities to adapt work, work organization and work environment to workers;
2) opportunities to eliminate hazards and reduce OH&S risks;
b) other opportunities for improving the OH&S management system.
In HIRAC form, OH & S opportunities shall be identified by appropriate HIRAC team. It shall be
considered as planning action, thus action plan for such opportunities shall be prepared. This procedure
shall be implemented and maintained by Organisation.
Note: It is not necessary for all risk the opportunities shall be identified.

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C) Decide on precaution/ Determining Risk Control Measures

Eliminate Design to eliminate the Hazard e.g. mechanized


instead of manual work.
Substitute Substitute the Hazardous Substance, Machine or Tasks
with a less hazardous one
Increasing Effectiveness of Control

Engineering
Modify/ Redesign Tools or Equipment, isolate/ enclose
equipment and put guards in place. Install ventilation
system, machine guarding, interlocks, sound
enclosures etc.
Administration Develop and implement Standards, safe procedures
and training for Hazardous Jobs, Safety signs,
hazardous area marking, photo luminescent signs,
marking for pedestrian walkways, warning sirens /
lights / alarms, safety procedure, equipment
inspections, access control.
PPE PPE such as Safety Helmet, footwear, Personal Fall
Arrest System, safety glasses, hearing protection, face
shield, respirators, gloves etc. can be important, but
should be a last resort
Eliminating the hazard: This is the most effective control and should always be attempted in the first
instance. If a hazard is removed from the workplace, the associated risk is completely eliminated. E.g.,
eliminating the need to work in a confined space.
Substitution: Involves replacing the hazard with one that presents a lower (and more manageable) risk.
That is, replacing the plant, product or processes that represent the hazard with something that does
the same job but has less potential to cause harm. E.g., using a hydraulic machine instead of electrical
power because of water at site.
Redesign: Involves changing the design of the workplace, equipment or work process. It involves
thinking about ways the work could be done differently to make the workplace safer. For example, using
damping or baffles to reduce exposure to noise and vibration; or using a track to hold a portable saw to
prevent back strains or sprains.
Engineering: Involves controlling the hazard at source, Isolating or separating the hazard from the
person, or the person from the hazard. E.g., install guarding on equipment or operating machinery
remotely.
Administrative controls: Involve minimizing exposure to a risk through the use of procedures or
instructions. It is often necessary to use these controls in conjunction with other measures. E.g., posting
warning signs or providing safety training.
Personal Protective Equipment (PPE): PPE is worn by people as a final barrier between them and the
hazard. This measure does not control the hazard at the source. E.g., using respiratory protection to
minimize exposure to inhalation of silica dust.

Step 4 Record Significant Findings (Register HIRAC)


Function/ projects shall document the HIRAC based on above mentioned process. It shall be duly signed
by respective person.
It’s suggested that document number of operational control procedure, procedures, etc. shall be
provided.
In case of High risk/ medium risk the OH & S Objective, target and programme may be prepared and
provide its reference number in the HIRAC.
HIRAC shall be recorded in “List of activity/ equipment/ plant/ machinery considered for preparation of
HIRAC register: TMT – 003 & TMT - 004”

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Step 5 Review assessment and update if necessary
The final step in the risk management process is to monitor and review the effectiveness of measures.
For this step, it can be useful to ask questions to determine whether:
 Chosen control measures have been implemented, as planned
 Chosen control measures are effective
 There are any new problems or hazards arising out of the controls implemented
 Risk rating needs revision (Team will decide)
This involves:
 Consulting with workers, supervisors and occupational health and safety representatives
 Measuring peoples exposure (e.g. taking noise measurement in the case of isolation of a noise
source)
 Monitoring leading and lagging indicator performance
Review: The Hazard identification and Risk assessment register shall be reviewed for only appropriate
activity with consideration of incorporating hazards due to any changes/ additions in the processes/
activities/ technology and after any accident / incident / near misses to prevent recurrence in the
location where the incident has happened and occurrence where there are chances of happening of
similar incident, after non-conformance findings through audits and after negative observations made
during emergency drills. However, Minimum annual review of HIRAC shall be done for future/ existing
activities/ product/ services for only appropriate activity.
In case of any updation with reference to any incident or process change, legal changes, outcome of
audit/ inspection report, etc., it is suggested that a reference of the same may be provided. The
amended text may be reflected by revision no. (R0)/ (R1)/ or by bold font etc.

Implementation of Control Measures


A documented OHS control procedure shall be prepared for implementation of control measures.
Implementing control measures involves:

 Developing Standards, Procedures


Develop work methods and procedures in consultation with the workmen to make sure that the
control measures are effective. Management, supervisor and worker responsibilities need to be
clearly defined in the work procedures.
 Communication
Inform workers and others about the control measures to be implemented. It is important to clearly
communicate the reasons for changes.
 Providing training and instruction
 Provide training and instruction to the workers, supervisors and others in relation to the new
control measures.
 Supervision
 Provide adequate supervision to ensure that the new control measures are in place and being
used correctly. Identifying At Risk behaviour (ARB) and correcting it immediately.
 Maintenance
Preventive Maintenance of lifting machines, equipment and vehicles play a very important role in
ensuring safe working environment. Work procedures will spell out maintenance requirements to
ensure the ongoing effectiveness of the new control measures. Records of maintenance will be kept.
Once the procedure is implemented then it is to be maintained by continuous awareness,
communication, training, participation, consultation and rigorous vigilance.

Doc. Ref: Template TMT – 003 and TMT – 004

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1.2.2 Environmental aspects, Impact Assessment and Control (EIAC)

Purpose: Environmental aspect/ impact assessment shall be done to assess the environmental impacts of
project activities and determine mitigation measures to nullify or minimize the impacts.
Scope and Application: All activities having significant environmental aspects/ impacts associated with it
and related to execution of Project of Organisation and its subsidiaries which includes offices and other
services.
Responsibility and authority: Department / Functional Head / Project Head/ Manager shall be

responsible for environmental impact assessment & control measures in their area of responsibility:
FLOW CHART:

Figure 1.2.2

Process Description: EIAC shall be prepared by Department / Functional Head / Project Head/ Manager
or their delegated line function staff including contractor’s staff at planning stage to eliminate, reduce
or isolate the potential hazards as well as to proactively organise resources before activity commence.

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When to prepare EIAC:
 Before execution of any work, plant or equipment.
 Before significantly changing a work practice or procedure.
 Before changing any activity or process, where the change may give rise to environmental
aspect/impact.
 Management of change
Form an EIAC team that comprises of Department / Functional Head / Project Head/ Manager or their
delegated line function staff including contractor’s staff to prepare the EIAC. The team member should
be appropriately trained for conducting EIAC.
Points to be consider while preparing EIAC: Legal requirements, activities, product, plant, machinery,
equipment, site conditions, work methodology, previous incidents history, company manual,
procedures, operational control procedures, change in activity, process, behavioural aspects; activities,
products and services that it can control and those that it can influence, and their associated
environmental impacts, considering a life cycle perspective, etc.
Before initiating EIAC, method statement with details activities may be considered. At least for key
activities, the method of statement shall be submitted by execution team to EHS team for input before
its finalization.

Steps for EIAC:


Step 1 Identification / Classification of the Activities
Step 2 Identification of environmental aspects.
Step 3 Impact Assessment, Determining Significant/ Insignificant aspect/ impact and
Determine Risks & Opportunities
Step 4 Determining Control Measures & determining risks after control measures
Step 5 Documentation of Register of EIAC
Step 6 Reviews and Periodic updation
Steps of EIAC are detailed below:-
Step 1 Identification / Classification of the Activities
 Develop a list of process to be undertaken by the department.
 Break this process into a list of major activities & sub-activities.
 Get methodology, list of manpower, materials and equipment to be used for execution of this
activity & sub-activity.
 Determine whether activity is routine/ abnormal or potential emergency situation.
Step 2 Identification of environmental aspects
Construction activity requires usage of materials like water, cement, reinforcement steel bar, energy,
additives, chemical, etc. During the process various wastes are generated and losses incurred viz. noise
generation, waste of wood and steel scrap, waste water, natural resources depletion, etc. This process
is illustrated below:

INPUT OUTPUT

Various materials, water, Construction Acivities Building


Energy, chemicals

Loss / Discharge
Rejected materials; wastewater; emission; noise impact; waste material.

Various environmental aspects and its impacts that arises during construction activity, needs to be
identify.
Step 3 Impact Assessment, Determining Significant/ Insignificant aspect/ impact and Determine Risks &
Opportunities

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Environmental impacts of an environmental aspect associated with the project activity shall be assessed
based on the following pre-determined criteria:
 Scale of Impact (Sc)
 Severity of Impact (Se)
 Probability of Occurrence (Pr)
 Duration of Impact (Du)
 Operational Control of Impact (C)
 Legal Requirement (L)
For every environmental impact, the impact value shall be calculated based on above mentioned
criteria by using following formula:

Impact Value/ Impact rating cumulative weightage: [(Sc+Se+Pr+Du) * C] +L


After calculation of impact value, the impact value shall be compared with cut off impact value (20) to
determine whether it is insignificant aspect /Impact or significant aspect/ impact.
If impact value/score more than or equal to 20
And/ or
Impact is Significant (S) In case of any legal requirement.
Impact And/ or
Category In case of any reasonably foreseeable emergency situation.
If impact value/ score less than 20.
Impact is Insignificant
Or Absence of legal requirement.
(IS)
Or absence of any reasonably foreseeable emergency situation

Determine Risk Assessment & Opportunity before control measures


a. Risk Value = Severity X Probability;
b. Risk Value: 15-25: H (High Risk Level); 8-12: M (Medium Risk Level); 1-6: L (Low Risk Level)
c. Criteria for High Risk Condition (for risk without control measures):
At least any one condition applicable:-
Risk Value: 15-25 OR Legal: Applicable OR Emergency: Applicable.

Parameters for Environmental Impact Assessment


For the environmental impact assessment a 5-point scale is used. Parameters for Environmental
Impact assessment is explained below with an example.
Point Level Scale of Impact (Sc) Example
1 Low Impact is registered within 1 meter Generation of noise due to hammering
2 Moderate Impact is registered within 10 Generation of noise due to chipping (Using
meter mechanical equipment)

3 High Impact is registered within the Generation of noise due to unloading of debris
construction site (within 30m) from a debris chute
4 Very High Impact is registered within the Generation of noise due to breaking of
boundary of construction site boulders

5 Excessive Impact is registered outside the Generation of noise due to blasting of rock
construction site

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Point Level Severity of Impact (Se) Example
1 Negligible No lasting effects Leakage / wastage of water
2 Minor Acceptable effects Release of gases from vehicle within
permissible limits as stipulated by Statutes
3 Moderate Less significant adverse effects Release of gases from vehicle beyond
permissible limits as stipulated by statutes
4 High Significant adverse impact that Discharge of waste water from site to storm
may be prevented water drains, lakes, rivers, fresh water
channels, etc.
5 Major Irreversible adverse impacts Contamination of soil due to spillage of acid/
irritants/ solvents

Poin Level Probability of Impact (Pr) Example


t
1 Negligible Occurs once in a year Discharge of battery waste/ E-waste
2 Low Occurs once in month Generation of wood/ paper/ plastic waste
3 Moderate Occurs once in a day Hammering/ drilling activity
4 High Occurs several number of times in Air pollution due to emission from material
a day hoist equipment
5 Major Occurs continuously in a day Air pollution due to Gas emission from
welding

Point Level Duration of Impact (Du)

1 Negligible Impact observed instantly


2 Short Impact observed for a day
3 Moderate Impact observed for 1 month
4 Long Impact observed up to 1 year
5 Catastrophic Impact observed more than a year

Poin Level Operational Control of Impact (C) Example


t
1 Available and Any control measures implemented to Binding dust through moistening the
Effective maintain the environmental parameters soil, e.g. with sprinkling of water
like air, water, noise, land contamination
within limits
2 Mechanism in Any control measures implemented to Incineration of paper/ wood waste
place but not maintain the environmental parameters rather than collecting the paper waste
practiced/ like air, water, noise, land contamination and give it to authorized agencies for
Partially within limits but not implemented recycling
practiced

3 Absent or not No control measures is implemented to No control measures has been


effective maintain the environmental parameters implemented to collect the fumes
like air, water, noise, land contamination generated due to welding activity
within limits but not implemented

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-002, Rev No: R1

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Point Level Legal Requirement (L) Example

1 Not No legal requirement is applicable Capture, extract (e.g. spot suction)


Applicable to and filter the emitted fumes from
Legal welding activity
Requirement
10 Applicable to A applicable legal requirement which has Generation of 95db (A) noise from
Legal to be followed from Environmental Diesel Generator exceeding the noise
Requirement Protection act, Central pollution control limit of 75db (A) specified in Central
board, Motor Vehicles act, etc.… Pollution Control Board.

Step 4 Determining Control Measures & determining risks after control measures
Various control measures can be adopted like
 Engineering control (enclosure to DG set to control noise, filter to control pollution, etc.),

 Administrative control (training, awareness, etc.),

 Substitution control (use of electronic document in place of paper work).

 3 R: Reduce, Reuse and recycle approach shall be considered while managing waste.

In case of significant aspects, multiple, effective and efficient control measures are recommended.
Determine the risks value after existing control measures with similar way as determined in previous
step.

Environmental Planning actions:


Environmental planning actions is being done with consideration of
a. Significant environmental aspects

b. Compliance obligation

c. Risk and opportunities

While planning for actions, following factors is being considered:


a. Technological options

b. Financial options

c. Operational options

d. Business options

Further control measures as a part of EIAC where environmental planning actions is identified. In
further control measures comprises of sections for planned activities, responsibilities, target date and
status.

Step 5 Documentation of Register of EHS EIAC


Function/ projects shall document the EIAC based on above mentioned process. It shall be duly signed
by respective person.
Step 6 Reviews and Periodic updation
The final step in the EIAC process is to monitor and review the effectiveness of measures. For this step, it
can be useful to ask questions to determine whether:
 Chosen control measures have been implemented, as planned
 Chosen control measures are effective

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 There are any new problems or hazards arising out of the controls implemented
 Risk rating needs revision (Team will decide)
This involves:
 Consulting with workers, supervisors and occupational health and safety representatives
 Measuring peoples exposure (e.g. taking noise measurement in the case of isolation of a noise
source)
 Monitoring leading and lagging indicator performance
The EIAC register shall be reviewed at least yearly basis for incorporating aspects/ impacts due to any
changes/ additions in the processes/ activities and after any chemical spillage/ emergency, etc. to
prevent recurrence in the location.

Doc. Ref: Template TMT – 003 and TMT – 004

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-002, Rev No: R1

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