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Nº: SP14 Page.

: 1 of 20
EHS Inspections and Audits
Inspeksi dan Audit EHS Classification: Critical Rev .: 03
Klasifikasi: Penting

RIWAYAT REVISIS/ REVISION HISTORY

Indeks Revisi Subjek Dikeluarkan oleh Tanggal Penerapan


Revision Index Subject Issued by Date of Application

01 Initialization
Section 6 added. “SLA” changed to
02 Mathew Orr May 2009
“EHS Inspection”.
Major update to align with current
03 regulations and Vale Integrated A Ashar 02/08/2018
Management System

Persetujuan:
Tanggal
Approval:
peninjauan
Manager Engineering 02/08/2020
berikutnya:
and Construction and
Abu Ashar Next review date:
EHS

Penanggung Jawab: Khalayak Sasaran: Semua karyawan PT Vale


Indonesia TBK dan Kontraktor
Responsible Person: All Managers & Project
Managers Target Audience: All PT Vale Indonesia Tbk and
Contractor Employees responsible

Penanggung Jawan Teknis: Tanda Tangan:


Technical Responsible: Approval:

Budiawansyah
Manager Emergency Response and EHS
Penanggung Jawan Teknis: Tanda Tangan:
Technical Responsible: Approval:
Aris Ambodo
Manager Environment

Kata Kunci: SOI, JCC, Audit, Inspeksi.


Key words: SOI, JCC, Audit, Inspection.
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LIST OF CONTENT
1. OBJECTIVE ...................................................................................................................................3
2. APPLICATION ...............................................................................................................................3
3. REFERENCES ...............................................................................................................................3
4. DEFINITIONS ................................................................................................................................3
5. ROLES AND RESPONSIBILITIES / ...................................................................................................4
6. INSPECTION, OBSERVATION AND AUDIT OVERVIEW /....................................................................6
7. UNPLANNED INSPECTIONS AND OBSERVATIONS / ........................................................................7
8. PLANNED EQUIPMENT, FACILITY AND WORKPLACE INSPECTIONS / ..............................................8
9. PLANNED BEHAVIOR AND CONDITION INSPECTIONS .................................................................. 10
10. INSPECTION & OBSERVATION COMPETENCIES ........................................................................... 12
11. EHS AUDITS ............................................................................................................................... 13
12. REPORTING INSPECTION AND AUDIT FINDINGS .......................................................................... 16
13. CORRECTIVE ACTION AND RISK MANAGEMENT ......................................................................... 16
14. MONITORING AND REVIEW OF INSPECTION AND AUDIT PROGRAM ............................................. 16
15. RECORD KEEPING...................................................................................................................... 17
APPENDIX 1: WORKPLACE INSPECTION REQUIREMENTS ................................................................... 18

TABLE OF FIGURES

Figure 1: Worker Inspection and Hazard Control ........................................................................................ 4


Figure 2: PTVI EHS Inspection, Observation and Audit Program .................................................................. 6
Figure 3: Hazard Inspection Form (from the PARA booklet) ......................................................................... 7
Figure 4: The Systems Matrix ................................................................................................................11
Figure 5: PTVI 10 Step Audit Process .....................................................................................................15

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1. OBJECTIVE

This procedure defines the EHS inspections and audits that are carried out at PT Vale Indonesia (PTVI) and
describes how they are conducted. The intent of inspections and audits is to verify compliance with the EHS
Management System aswell as to promote continuous improvement.
This procedure will focus on the requirements for the following inspection and audit activities:
• Manadatory EHS Inspections and Observations e.g. Job Cycle Check, Safety Observation-Inspection (SOI).
• PTVI Department and Project specific workplace inspections e.g. equipment, factilities and the work
environment.
• Internal and External EHS Audits.

2. APPLICATION

This Procedure applies to all employees and contractors working for PT Vale Indonesia TBK.

3. REFERENCES

1. Legal:
• Decree of the Minister of Energy and Mineral Resources No. 1827/K30/MEM/2018 on Guidelines for the
Implementation of Good Mining Practices.
2. Vale:
• PTP-000834 IMS Inspections and Audits Management.
• PRO-022630 Manage Nonconformities, Preventive and Corrective Actions.
• PRO-001-BM HSE Incident Reporting (Base Metals).
3. PT Vale Indonesia:
• INS-003-VIEHS Accountabilities for Safety and Behavior.
• PTVI Major Hazard Standards.
• PTVI EHS Standards.
o EHS 06 EHS Risk Management.
o EHS 14 EHS Compliance Obligations.
o EHS 21 Non-Conformity Corrective and Preventive Action Management
o EHS 10 EHS Accountabilities.
• PTVI Guideline for EHS Management System Auditing

4. DEFINITIONS

As Low as Reasonably Practicable (ALARP): A term used to describe a level of control which is reasonably
practicable, meaning that which is, or was at a particular time, reasonably able to be done, taking into account and
weighing up all relevant matters including:
a. The likelihood of the hazard or the risk concerned occurring; and
b. The degree of harm that might result from the hazard or the risk; and
c. What the person concerned knows, or ought reasonably to know, about:
(i) The hazard or the risk; and
(ii) Ways of eliminating or minimising the risk; and
d. The availability and suitability of ways to eliminate or minimize the risk; and

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e. After assessing the extent of the risk and the available ways of eliminating or minimizing the risk, the cost
associated with available ways of eliminating or minimising the risk, including whether the cost is grossly
disproportionate to the risk.
Audit: Systematic and documented verification process, performed to obtain and evaluate the performance and
the degree of compliance with the requirements of Environment, Health and Safety Management System.
Audit Criteria: Set of policies, procedures or requirements used as a reference for comparison against the audit
evidence.
Audit Scope: Coverage and limits of an audit that must include the description of the physical locations,
organizational units, activities and processes, as well as the time period covered.
Corrective Action: Action to eliminate the cause of a detected nonconformity in order to prevent their re-
occurance.
Inspection: Documented verification of the aspects and risks of Environment, Health and Safety, including
workplace conditions, systems, and equipment and control devices.
Unplanned Inspection: An inspection carried out during the normal conduct of work to assess workplace
conditions and behaviors. This does not need to be documented on a specific inspection form.
5. ROLES AND RESPONSIBILITIES /

All Workers
• Inspect the workplace and equipment when:
• Entering the workplace.
• Starting a new task or re-commencing a task after a rest break.
• Prior to using potentially hazardous equipment.
• Communicate to other workers any hazards that may affect them.
• Make appropriate notifications, erect barriers and prevent work in any unsafe areas until they are made safe or
the level of risk is reduced to an acceptable level.
o If action is required to control a hazard, workers must assess the situation and only take action if they are
competent to do so, and can do so safely. Otherwise they should seek assistance.

o Inspect
1. 2. Control 3. Stop Work if 4. Report
Required

After arriving at the - What risk does the If you cannot control the Using the PARA/ SOI
workplace inspect hazard present? hazard and there is hazard form, report
the work location, - Can it be controlled potential for injury or the hazard to
equipment and immediately? environmental harm. supervisor
facilities to identify - Reduce the risk to - Stop work. (Figure 3).
hazards. ALARP. - Make the area safe.

Figure 1: Work er Inspection and Hazard Control

Supervisors
• Inspect active work areas under their responsibility atleast once per shift; based on risk and condition of the
area, the frequency of inspections may increase.
• Conduct inspections, audits and tests as per their legal and PTVI responsibilities.
• Prepare and sign reports on investigation, audit, and testing.
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• Ensure that investigation, examination and testing of mining facilities, infrastructure, installations, and
equipment are always performed (Technical Supervisors).
• Conduct investigation, audit and testing of facilities, infrastructure, installations, and equipment prior to being
used, after reinstallation, and/or repaired.
• For uncontrolled hazards that have been reported to the the supervisor, they must:
1. Assess the potential impact of the hazard.
2. Take appropriate action to protect workers from an unacceptable level of risk.
3. Follow department processes to have the hazard logged in SAP with corrective action/s assigned.
4. Communicate the relevant information about hazards and controls to the oncoming shift.

All Management/ Leaders


As part of visible leadership and to understand the hazards and risks of their areas of responsibility, managers must
devote some of their time to conduct unplanned/ unstructured inspections in the workplace.
Inspections provide an opportunity to engage with workers and supervisors to discuss risks in the workplace and
to reinforce PTVI expectations for hazard and risk management and for working in accordance with site Standards.

Department/ Project Managers


• Define the targets for Planned EHS Management Inspections (JCC, MHS) for their subordinates.
• Identify locations, equipment, facilities and tasks to be subject to regular workplace inspections.
• Schedule inspections and audits in accordance with this procedure and the risks present in their areas of
responsibility.
• Allocate responsibility for completing workplace inspections and audits to relevant and competent persons in
the workplace.
• Use risk management principles to prioritise correction of non-conformities.
• Monitor the creation and close out of actions for identified non-conformities.
• Authorize employees to participate in training on EHS inspections and audits.
• Perform an annual review of the results of EHS audits, as well as corresponding action plans, to evaluate the
effectiveness of actions implemented in line with the continuous improvement process.
• Review inspection checklists under their control in accordance with PTVI document management requirements.

EHS Manager
• Arrange for completion of EHS audits as required by Vale Global and Base Metals aswell as legal requirements.
• Join health and safety inspections, when called upon to do so.
• Support business areas in correcting identified hazards and non-conformities.
• Consolidate and analyse the results of health and safety audits and inspections for management review.
• Collate data on inspection and audit KPIs for presentation to the PTVI EHS Committee.
• Report annually to the EHS Committee on the EHS Inspection and Audit program.

EHS Committee
• Provide input into setting the targets and objectives of PTVI’S inspection and audit program.
• Monitor performance against inspection and audit targets and objectives.

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• Monitor the implementation of action plans related to critical EHS audit findings.

COO
• Assign areas of responsibility to appropriate Managers so that all areas of the operation are under an inspection
program. Any unassigned areas of responsibility will remain the responsibility of the COO.

6. INSPECTION, OBSERVATION AND AUDIT OVERVIEW /

The PTVI inspection, observation and audit program can be grouped into three separate actitivies:
1. Unplanned inspections and observations.
2. Planned workplace inspections:
• Inspections of the facilities, infrastructures, installations and equipment, and the working environment.
• Behavior and condition inspections, including Job Cycle Check and Major Hazard Standard inspections.
3. Internal and external EHS audits.
An overview of these is detailed in Figure 2 below. How these programs are implemented is detailed in sections 7
and 11 of this procedure.

Unplanned • Conducted by all personnel; including staff, non-staff, contractors and management.
Inspections & • Findings documented using:
Observations - PARA/ Hazard Inspection Form: Normally used by workers in the field.
(Section 7.1) - Safety Observation-Inspection (SOI): Normally used by supervisors and managers.

• Includes mandatory inspections on Housekeeping, Hydrocarbon, Waste


Management and Run-Off.
• Pre-start and periodic inspections of equipment, facilities, installations, infrastructure
and work locations.
Environment, • Inspection and calibration of measuring, inspection and testing equipment e.g. air
Equipment, quality monitors and noise dosimeters.
Facility and • Examples include inspections of the following:
Workplace
Inspections - Lifting, rigging and electrical equipment.
- Vehicles and mobile equipment. - Fire fighting equipment and services.
(Section 7.2)
- Fire fighting equipment and services.
- Health and hygiene inspections and monitoring.
- Chemical storage areas.
- Mining and other operational areas.

• Planned Inspections by Management to engage with workers, and monitor and


Behaviour and correct workplace conditions and activities.
Condition
Inspections • Completed using the following processes/ tools:
- Job Cycle Check (JCC).
(Section 7.3)
- Major Hazard Standard inspections.

• Planned internal and external audits of the PTVI EHS Management System.
• Examples include:
EHS Audits - Vale Corporate EHS.
(Section 8) - Mine Safety No.1827/K30/MEM/2018 (internal and external)
- PROPER.
- PTVI Major Hazard Standard Audits.

Figure 2: PTVI EHS Inspection, Observation and Audit Program

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7. UNPLANNED INSPECTIONS AND OBSERVATIONS /

7.1. HAZARD INSPECTIONS


All workers (including contractors, non-staff and staff)
are expected to continually monitor their working
environment, to identify and to manage hazards and
risks that may lead to personal injury or harm to the
environment or physical assets.
Workers should use the Hazard Inspection Form
(Figure 3) to document and report hazards; the form is
included in the PTVI Personal Activity Risk Analysis
(PARA) booklets. These can be completed by any
worker and handed to their Supervisor for further
management.

Figure 3: Hazard Inspection Form (from the PARA booklet)

7.2. SAFETY OBSERVATION – INSPECTION (SOI)


Reporting findings from unplanned inspections can also be done using a Safety Observation – Inspection (SOI)
form. SOIs serve a similar purpose to the Hazard Report Form, but are generally completed by Supervisor level
and above.
SOIs can be used to assess and record both Unsafe Conditions and Unsafe Behaviors
Whether completing a SOI to manage an unsafe behavior or condition, the key steps to follow are:
1. Observe: Observe the work task/ condition. The SOI form can be used to guide your observations.
2. Identify: Identify any unsafe conditions or behaviors and uncontrolled hazards.
3. Act: Interact with the workers, discussing any positive observations aswell as areas for improvement/ non-
conformities.
4. Document: Document the findings and upload the results into SAP for corrective action monitoring.

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8. PLANNED EQUIPMENT, FACILITY AND WORKPLACE INSPECTIONS /

Planned EHS inspections are a planned event in which


the workplace is inspected to identify potential hazards. It
is the best way of proactively identifying hazards before
they have the ability to cause harm to people, the
environment or physical assets.

8.1. PLANNING INSPECTIONS


Department and Project Managers with support from the EHS Department are to establish department inspection
programs. These programs should address all locations, facilities, infrastructures, installations, equipment within
their areas of responsibility that have the potential to cause harm.
Inspection programs should be planned in advance to make the inspections effective, thorough and integrated into
Department’s overall EHS program. In planning the inspection program, the following steps should be followed and
relevant detail defined:
1. Identify the type and frequency of inspections to be done.
2. Identify who will perform the inspection.
3. Detail what the inspection will include.
4. Determine how the results are recorded.
5. Report findings (refer to section 12).
6. Corrective action management (refer to section 13).

8.2. INSPECTION TYPES AND FREQUENCY


Assess department/ project operations to determine the types of inspections required and how often to do the
inspections. Typically these types of inspections are done either periodically, e.g. daily or monthly, or done prior to
using a particular type of machine.
To assist in identifying inspection requirements, managers should consult the following:
• PTVI EHS Standards, Major Hazard Standards and Standard Procedures.
• Specifications such as ESPs, ISPs and MSPs.
• Supplier/ manufacturer information.
• Legislation and adopted local and international standards.
• Annex 02 of Vale document IMS Inspections and Audits Management procedure (PTP-000834), refer to
APPENDIX 1: WORKPLACE INSPECTION REQUIREMENTS).
NOTE: In case of conflict between the law and the PTVI EHS MS requirements, the most restrictive shall be applied.

8.3. IDENTIFY WHO WILL DO THE INSPECTION


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Assess who has the skills required to perform a particular type of inspection. In some instances, this may require
bringing in third parties to the inspection. An inspector should have:
• Training in how to perform inspections.
• Knowledge to identify the types of the hazards that may exist in that location or with the type of equipment.
• Awareness of previous injuries and illnesses at the workplace.
• Understanding of work processes, equipment, products and bi-products.
• Familiarity with laws that apply to that workplace/ equipment etc.
• Knowledge and understanding of PTVI EHS Standards.
• Ability to make recommendations for corrective action.

8.4. IDENTIFY WHAT THE INSPECTION WILL INCLUDE


Departments need to identify which checklist shoud be used, and may need to create new checklists if standard
PTVI inspection forms aren’t available. In addition to identifying the checklists, consideration should be given to the
following:
• What testing methods and equipment will be used.
o All inspection, measuring, and test equipment that may be used to monitor health, the environment and the
workplace shall be calibrated and inspected in accordance with manufacturers requirements and based on
risk/ operational experience.
• What hazards needs to be be included:
o Safety hazards and/or components: ousekeeping hazards, wet floors, loose electrical cables, objects
protruding in walkways or doorways.
o Biological hazards such as mould, fungi, bacteria, viruses, parasites.
o Chemical hazards that come in liquid, solid, vapour, gas, dust and fumes.
o Ergonomic hazards such as awkward positions, static posture, forceful and repetitive movement.
o Physical hazards such as heat, cold, noise, light, energy sources.
o Psychological hazards such as heights, loud sounds, confined spaces, bright lights.
o Radiation hazards such as electric welding flashes and sun burn.
o Environmental hazards: Room temperature, ventilation, contaminated air, some office plants.
o Equipment including machinery and tools, checking guarding, belts, etc.
Note: Refer to APPENDIX 1: WORKPLACE INSPECTION REQUIREMENTS for additional guidance.
• Is there PPE to be inspected.
• Do the inspector need to have supporting documentation such as prior inspection reports, maintenance
schedules, incident investigations with them.

8.5. RECORD FINDINGS


Inspectors must record the findings and observations made during the inspection. Where hazards were identified,
provide specific details and the location of hazards and recommendations for action where appropriate.
Departments must determine who will recieve copies of inspection reports, so that prompt action is taken.

8.6. HOUSEKEEPING, HYDROCARBON, WASTE MANAGEMENT AND WATER RUNOFF


INSPECTIONS
PTVI’s EHS Department has developed inspection forms for the following practices.
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• Housekeeping (form on SAP).


• Hydrocarbon storage facilities (refer to EHS01 Hydrocarbon Management).
• Hazardous waste management (refer to EHS02 Waste Management).
• Control of land disturbance, and management of runoff (refer to EHS03 Runoff Water Management).
These forms must be used when applicable in each department/ project.

9. PLANNED BEHAVIOR AND CONDITION INSPECTIONS

Planned Behavior and Condition inspections are


conducted by PTVI Supervisors and Managers.
These inspections aim to:
• Promote Zero Harm behaviour and work practices
that are in accordance with PTVI standards.
• Verity the provision of fit for purpose equipment.
• Verify work procedures are accurate and complete.
• Create a sense of EHS ownership in all employees
and contractors.
PTVI uses two tools to conduct these inspections:
• Job Cycle Check (JCC).
• Major Hazard Standard (MHS) Inspections.
As with other types of inspections, department and project managers should develop a plan for conducting these
inspections.
During the planning phase, managers should review the risk register of their department or project/s. Additionally,
they should consider the list of issues below and how they relate to their operations. This will help to identify areas
of greatest EHS Risk exposure, highlighting areas where their attention is needed most and to confirm that all
critical areas are included in the inspection program.
• Identify all significant health, safety and environmental hazards.
• Work locations:
o Identify locations where hazardous equipment, facilities and installations are found.
o Be sure to also identify locations that are located far away from the main operational office/ site that may
not receive regular management supervision e.g. exploration or tree clearing activities.
o Higher risk locations should be inspected more regularly. However all areas, should be inspected over a
period of time.
• Work force: The program should include PTVI workers and contractors when appropriate.
• Work tasks:
o Higher risk work tasks should be inspected more regularly than lower risk tasks.
o Identify higher risk tasks that my only occur infrequently. Be mindful to deviate from your plan and aim to
inspect these activities should they occur e.g. recovering overturned vehicles, responding to chemical spills,
complex crane lifts.
o Conduct inspections across each work shift, including night shift.
o Review project / department work schedules to plan inspections based on current risks e.g. A project may
be in an earthworks phase, so inspections may focus on mobile equipment operation and sediment control.
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It’s important to be flexible with the plan as the year progresses. Managers should adjust plans if the risk profile of
the area changes. Some examples of when a plan may be adjusted includes:
• To increase focus on a specific activity after a criticial incident or a series of near hit or lower consequence
incidents of similar circumstances.
• After a significant change e.g. after the introduction of a new work task or item of plant.
• In response to a major audit finding or recommendation.
The followign two sections, provide an overview of the JCC and MHS inspection processes.

9.1. JOB CYCLE CHECK (JCC)


The purpose of the JCC program is to provide a system that will:
• Look at the EHS and Quality aspects of operating procedure or practice.
• Keep procedures current and adequate.
• Ensure that employees know the procedures and practices.
• Provide refresher training for personnel.
The JCC process assists PTVI in maintaining work practices that are authorised and productive (refer to cell A of
the systems matrix below).

Figure 4: The Systems Matrix


The process of conducting a JCC is described in the following steps:
1. The supervisor selects the procedure to be checked and makes a copy of it.
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2. The supervisor selects an employee and sits down away from the job site, with the employee to review the
purpose of the JCC. Then the supervisor and the employee review the procedure.
Note – this must be done the very first time a supervisor does a job cycle check with an employee so that the
cooperative nature can be stressed. After the first contact, the supervisor may skip the pre-inspection review of
the procedure with the employee and go directly to watching the employee actually doing the job or task.
3. The supervisor and the employee will go into the area and the employee will perform the job as described by
procedure.
4. Identify and document the following:
o Differences in how the job is done verses what the procedure says. If parts of the job cannot be done by
procedure, or if the normal practice does not follow the procedure, but is safe, note how the job is really
done.
o Any unsafe items such as striking hazards, defective equipment, lack of needed equipment, no escape
routes, inadequate space to do the job, lack of line of fire identification, etc.
o Any parts of the job that are not covered by procedure, but should be covered.
5. The supervisor and the employee sit down and review their initial findings and discuss the on-the-job evaluation.
The supervisor solicits suggestions from the employee.
6. If the employee needs additional training, the supervisor reviews that with the employee and tells the employee
when he or she will get the training.
7. The job cycle check form is then filled out. If minor revisions are identified, they are written on the photocopy of
the procedure, attached to the job cycle check form and then sent to the area procedure coordinator. If major
revisions are needed, a brief statement is made on the job cycle check form stating what is needed and why.
8. The supervisor and employee should agree that if the procedure is adequate, the employee will do the job by
procedure. If the procedure is not adequate, as soon as it is revised, the employee will follow the procedure.
9. The supervisor will complete the job cycle check history for the employee.
10. Whenever changes are made to operating procedures, the supervisor must ensure that his or her employees
are aware of all changes.

9.2. MAJOR HAZARD STANDARD INSPECTIONS


MHS inspections focus on critical aspects of each MHS that Leaders can use to assess behavioural compliance to
the MHS, critical equipment specifications and conditions aswell as procedure content. Departments should identify
which MHS are applicable in their areas and plan to conduct regular MHS inspections.
There is a specific inspection checklist for each MHS. The inspection forms focus on the most critical aspects of
the MHS, and generally include no more than 10 items that should be reviewed during the inspection.
People using the checklists need to be familiar with the content of the relevant MHS or be assisted by someone
with the relevent knowledge.

9.3. PLANNED INSPECTION CHECKLISTS


Each type of inspection and audit should be recorded in a specific form/ checklist. Documents should be controlled
documents and reviewed at periodic intervals to ensure on-going suitability, in accordance with INS-0003-PTVI
Instruction for Document Management.
Any changes to the workplace should trigger a review of the inspection and audit program and checklists.

10. INSPECTION & OBSERVATION COMPETENCIES


Workers required to conducted inspections and obervations should be trained and assessed as competent in the
competencies detailed in Table 1 below.

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Additional training and qualifications may be required for some inspections such as inspecting rigging equipment
or mining areas. Department managers should identify these competencies and ensure inspectors have fulfilled the
relevant requirements (whether they are PTVI or third party). Manadatory training requirements are also detailed in
PTVI’s Major Hazard Standards.
Table 1: Inspection and Observation Competencies

Competency PTVI Course Code


• SOI (Safety Observation - Inspection)
TSEHSJOBSA
• Job Cycle Check

11. EHS AUDITS

11.1. TYPES AND SCHEDULE


The Department Manager EHS is responsible for
implementing the PTVI Audit Schedule in accordance
with legal and Vale requirements.
A summary of internal and Vale EHS audits is provided in
Table 2.
A summary of external and Government audits is detailed
in Table 3.
PTVI Departments must identify any additional audits that
need to be applied in their areas e.g. Audits of the airport.
This shall be based on the risk profile of the area and in
accordance with PTVI and legal requirements.
Department/ project audit programs should include
internal audits (1st party), audits of suppliers (2nd party)
and external audits of PTVI operations (3rd party).
Table 2: Internal EHS Audits

Audit Title and Audit Tool/ Document By Who Frequency Reporting


Requirements
PTVI EHS MS Government audit PTVI, or 3rd Party Annually. • PTVI.
compliance to No. template. KAIT certified • Vale Global.
1827/K30/MEM/2018. auditor/s.
• KAIT (within 14
business days).
EHS/ MHS Standard PTVI EHS/ MHS Audit PTVI, or 3rd Party, Based on PTVI
Audits template. arranged by EHS EHS KPI’s.
Department.
PTVI EHS Integrated PTVI or 3rd Party Annually. PTVI
Management System PTP-000834 IMS arranged by EHS
Audit. Inspections and Audits Department.
Management - Annex Vale Global Audit 3 Yearly. • PTVI
01 HSE Protocol. Team. Or After a • Vale Global.
fatality.

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Table 3: External EHS Audits

Audit Type/ Description By Who Frequency Reporting Requirements


PTVI EHS MS compliance to KAIT approved 3rd Party, Upon request by • PTVI.
No. 1827/K30/MEM/2018. arranged by EHS KAIT. • Vale Global.
Department.
• KAIT (within 14 business
days).
Environment Management 3rd Party, arranged by EHS 3 Yearly. • PTVI.
System (EMS) Diagnostic Department. • Environment and Foresty
Audit. Ministry (KLHK) – For
Green Proper.
Energy Management System 3rd Party, arranged by EHS 3 Yearly. Environment and Foresty
(EnMS) Audit. Department. Ministry (KLHK) - For Green
Proper.
Installation Inspection & 3rd Party, arranged by EHS 3 Yearly. Labour Ministry.
Testing (Chemical Storage Department.
Locations).
Chemical Factor Inspection & 3rd Party, arranged by PTVI Annually. Labour Ministry.
Testing. Hospital.
PROPER. Environment and Forestry Annually. Environment and Foresty
Ministry (KLHK). Ministry (KLHK).

11.2. INTERNAL AUDIT TEAM SELECTION


The Department Manager EHS is responsible for ensuring the selected auditors of their disciplines are competent.
Competence may be achieved through attendance of external audit courses or knowledge of the activity to be
audited. The minimum competencies for auditors are shown in Table 4.
Table 4: PTVI Auditor Competencies

Audit Qualification PTVI Course Code


OHS Internal Auditor EHS0000052
EHS MS Lead Auditor (ISO 14001, OHSAS 18001) To be developed
PTVI MHS Auditor To be developed
PROPER Internal Auditor To be developed

A Team Leader will be nominated for scheduled audits. It is the responsibility of the Audit Team Leader to select
additional audit team members if required. The audit team may include representatives from line management
commensurate with the intended scope and the risk.
The Team Leader will be responsible for conducting and reporting on the audit as well as follow up/close out of
actions arising.

11.3. INTERNAL AUDIT PROCESS – 10 STEP MODEL


Most audits can be conducted by following the following 10 step model, as shown in Figure 5. These 10 steps are
described in detail in the PTVI Guideline for EHS Management System Auditing. These steps are provided for
guidance only, it is not mandatory for all audits to follow each of the 10 Steps; for example some audits may be
limited to systems/ documentation only, or a re-audit may not be required in some instances.

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• Planning and Preparation


1
• Pre-Audit
2
• Opening Meeting
3
• Systems Audit
4
• Physical Audit
5
• Evaluation of Findings
6
• Feedback & Closing
7
• Report
8
• Corrective Action Management
9
• Re-Audit
10

Figure 5: PTVI 10 Step Audit Process

11.4. EHS STANDARD AUDITS

11.4.1. PURPOSE
The purpose of EHS Standard audits is to measure compliance against all outcomes prescribed by specific EHS
Standards. Examples include the MHS audits, and hydrocarbon and waste management audits.

11.4.2. OVERVIEW OF THE PROCESS


An EHS Standard audit is conducted by completing an audit protocol. Each protocol contains a range of questions
that conform very closely to the complete set of requirements of the relevant Standard. These audits require
assessment of both physical condition, and system elements (generally by viewing documentation and conducting
interviews).
The protocols are designed to measure compliance in a consistent manner, so that differences in levels of
compliance between Departments can be measured. This also allows for consistent and accurate measurement of
compliance over time within Departments.
For this reason, only five possible scores for each requirement are allowed:
• 0% – No compliance to the intent of the requirement. No systems/ documentation or implementation.
• 33% – Systems/ documentation are in place, but not implemented.
• 67% – Systems/ documentation are in place, but not fully implemented.
• 100% – Systems (documentation) are in place and implemented.
• N/A – Not Applicable at the time of the audit

11.4.3. FORMS
The EHS audit protocols are available as Excel spreadsheets in the EHS MS.

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12. REPORTING INSPECTION AND AUDIT FINDINGS

Departments should define the reporting requirements for inspections and audits, identifying who will review reports
and who should be made aware of the findings, including:
• EHS department coordinator or their manager.
• Supervisor(s).
• Maintenance and/ or department/ project manager.
• Executive management.

13. CORRECTIVE ACTION AND RISK MANAGEMENT

13.1. CORRECTIVE ACTION MANAGEMENT


Resonsible managers shall implement processes so that issues from inspections, observations and audits requiring
corrective action are recorded in, and managed using SAP.
Vale procedure PRO-022630 Manage Nonconformities, Preventive and Corrective Actions describes the corrective
action management requirements at PTVI. Additional reporting on non-comfortities within Base Metals is detailed
in PRO-001-BM HSE Incident Reporting.
Control strategies shall be selected and implemented based on the hierarchy of control as outlined in EHS06 EHS
Risk Management.
Actions must be implemented by the people responsible as indicated in the action plan, observing the start and
finish deadlines for each action.
In response to audit findings, the relevant manager shall advise the Audit Team Leader on completion of corrective
actions, who will verify those actions prior to action close out.
It is the department/ project responsibility to:
1. Input actions into SAP.
2. Monitor action requests for their area of responsibility.
3. Ensure that actions are are completed by the due date.

13.2. RISK ASSESSMENT UPDATES


Managers, with support from the EHS Coordinator are to review and update department risk assessments/ risk
registers as a result of significant findings from workplace inspections, observations or audits. Updates may be
required if there is a change in hazards and risks present in the workplace, or if there is a change in the controls
used or the effectiveness of existing control measures. Refer to EHS06 EHS Risk Management for additional
guidance.

14. MONITORING AND REVIEW OF INSPECTION AND AUDIT PROGRAM

14.1. SITE WIDE MONITORING AND REVIEW


The Department Manager EHS shall, on a regular basis, provide feedback to PTVI Management regarding
performance against inspection and audit KPIs e.g. completion of JCCs vs the target. This shall include information
on the status of completed vs. planned inspections and audits for the site and other relevant findings.
The audit programme will be reviewed annually by the Department Manager EHS and a report prepared for the
EHS Committee. The report will include an assessment of:
1. Results of the internal audits..
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2. Audit resources, including auditor training.


3. Trends and results from audits.
4. Conformity with standards, legislation and procedures.
5. Potential means or ways to improve both the audit programme and the company EHS MS.
Improvements will be implemented as approved and will also be subject to feedback of their effectiveness in the
next annual review report.

14.2. DEPARTMENT/ PROJECT MONITORING AND REVIEW


For inspections and audits managed by Departments and Projects, the responsible Manager must implement
processes to monitor the completion of inspections and audits, including tracking planned vs. actual completion.
Compliance to the inspection and audit program must be reviewed at least monthly.
Management must implement corrective actions for maintaining compliance to inspection and audit schedules.

15. RECORD KEEPING

All inspection and audit records must be retained in accordance with INS-0002-PTVI Instruction for Record
Management.

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APPENDIX 1: WORKPLACE INSPECTION REQUIREMENTS

Annex 02: Vale PTP-000834 IMS Inspections and Audits Management

CATEGORIES CHECKS
Electrical installations • Physical conditions: grounding, connections, passages box, shields, plugs,
collective and personal protection, electrical installations are built, assembled,
operated, renovated, enlarged, repaired and inspected to ensure the safety and
health of users, etc.

Guarding of machinery • Adequacy of the guarding of sharp edges, pinch points, rotating components
etc., safe maintenance.
Work surfaces • Slippery floors, railings, w alkw ays, floors openings.
• Check opening floors and hatches;

Compressed gas cylinders • Segregation, storage, protection, signage.


Fuels • Conditions: Storage, ventilation, identification, protection against fire.

Emergency exits • Signage, visibility, lighting, clearances and training.


General
Physical Emergency show ers and • Flow , pressure, temperature, drainage, signage.
Conditions w ashers Eyes
Hand tools • General condition, storage, proper use.
• Condition of plugs, cables.
• Condition of lifting equipment.
• Calibration and registration.
• Oxy-cutter assemblies have flame-retardant valves. Stored properly in strollers
or cages.

Scrap • Accumulation, removal, storage and disposal.


Corridors, and storage • Accessibility and demarcation is appropriate.
areas
Stacking and storage • Location, segregation, stability, and passages.

Layout, handling and • Check condition and suitability of w aste bins.


w aste storage • Mixing w aste and selective collection (standard colors for collectors).
• Waste area (floor, identification, w aterproofing, delimitation).
• Contamination in the soil and / or w ater due to failure in w aste disposal.
• Layout and disposal of w aste.
• Leakage of hazardous w aste to the soil (oil, grease, chemicals, etc.).
• Disposal and storage of w aste.
Water resources • Check cracks and leaks in control structures.
Environm ent (industrial w ater, drainage,
• Covers are in place, identification and internal / external cleaning of the control
septic tanks, w ater and oil
structures.
separator)
• Presence of visible oil in the effluent output of the control structure.
• Check the presence of contaminated soil near the control structure.
• Check silting of drainage channels and sediment containment boxes.
• Leakage and inappropriate use of w ater (taps, pipes, pumps, hydrants, etc.).
• Erosion and sediment along the end of the drainage channels.
• Check results of monitoring of effluents (SAO, ETE, ETA, ETEQ, and Air
Quality).

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Air quality and • Check emissions of "black smoke" on fixed and mobile sources.
atmospheric emissions • Check visible emission of particulate matter (dust) and effectiveness of the
control system.
• Check results of monitoring of air emissions.
Survey of environmental • Ensure that new activities, products and services w ere included in the LAIA,
aspects and impacts and APR, etc.
risk analysis

Soil • Signs of degraded areas and / or contamination may come to characterize


environmental liabilities.
Equipment and critical • The pow er generators are protected by containment basins in secluded area
systems w ith access ban for unauthorized persons
• Sew age Treatment Plant, Water Treatment Plant, Water Separator and Oil
Wastew ater Treatment Plant Chemical, Discarded Materials Center, Septic
tanks, dams and piles Dykes, Retaining Walls, Drainage, Fire Fighting System,
Manga filters.
Housekeeping • Cleaning and organization of the area, the existence of w aste, clear drainage
channels, w ater leaks and w astew ater, signaling / identification cards, free and
clear access.
• Areas are organized and w ith enough space to carry out the w ork
Detection and alarm • Installation, sufficient coverage and functional testing.
against fires
Sprinklers • Spaced according to the type of storage, pressure and volume of w ater, proper
maintenance.
Fire evacuation • Escape route map, alarms, emergency lighting, simulations and staff training.

Portable extinguishers • Type and correct installation, location signs and instructions, expiry date,
Prevention demarcation, access, inspection, training.
and
Fire containment • Fire doors, ventilation controls, FES training,
Em ergency
Control Fire notification • Adequate communications.
Fire services • Hoses, valves and adequate w ater supply and compatible w ith the FES
equipment and periodic testing operation.
Fire fighting equipment • Color-coding, signage and adequate access, compliance w ith government
regulations.
Leak containment • Containment dikes: blocked and controlled drain valves, sealing, structure and
internal cleansing. Kit containment and collection.

Ventilation • Operation and effectiveness.


Lighting • Operation and effectiveness.
Collective protection • Operation and effectiveness.
equipment
Occupational
Health Personal protection • Selection, location and proper use.
equipment
Occupational hygiene • The program to monitor compliance: environmental and ergonomic agents (see
Instruction for Analysis and Risk Management), and health condition of the
people (see Instruction for Health Management).
Process safety • Identification and monitoring of critical process variables (pressure,
temperature, levels, among others.).
Safety
• Taking preventive measures in line w ith movements in monitoring.
• Task compliance checks its ow n procedure.
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• Are employees informed of the risks in their w orkplaces?

Hazardous substances • Labels of containers, storage, disposal and spill cleanup.


• Leaks in tanks, containers, drums, pumps, valves, pipes.
• Point of oxidation (rust) in drums and tanks.
• Tanks grounding existence.
• Condition (w aterproofing) of containment basins, buffer tank, w ater separator
and oil.
• MSDS arranged next to products.
• Existence of valves and records in containment systems and are Closed.
• Inventory of existence and proper storage of chemicals (incompatibility).
• Safety signs (risk label and safety panel).
• Availability of emergency kit for leakage mitigation.
• The storage sites of hazardous and / or explosive materials have good
ventilation, lighting, explosion proof, signaling, signage and no smoking.

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