Title Page
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Conducted on
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EHS Management Review
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Document No.
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Site Location
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Personnel Present
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Prepared by
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Location
Section 1.0 Program Management and Accountability
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1.1 Does the site have an EHS Policy in place? <br><br>Confirm posting or other communication of Policy Statement. Interview employees to evaluate awareness. The MTI Policy Statement may be used but must be signed as indicated.
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1.2 Is there at least one individual designated as the coordinator for EHS activities? <br><br>Determine if the EHS Coordinator is participating in the required activities, i.e. biweekly meeting, communicating Safety Alerts and Monthly Safety Summaries, etc.
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1.3. Have all employees attended a safety meeting at least monthly?<br><br>Review meeting attendance sheets and agenda.
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1.4 Has management established EHS goals and objectives for the site and are they related to meeting the goals stated in the EHS policy. <br><br>Compare actual and potential risks/aspects at site with the goals and objectives to confirm they are being addressed.
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1.5 Do all supervisors and managers have at least one activity based EHS goal? Is it included in the annual performance appraisal process and is it measurable? Note: one complete “cycle” of goals setting and performance appraisals must have been completed to be awarded any points.<br><br>A sample of job performance appraisal documents should be reviewed to evaluate effectiveness. Actual performance appraisal documents (with or without names covered) must be viewed to evaluate this element properly. Area Manager and Shop Supervisor interviews should be completed to confirm their awareness of the goals, and that they are being held accountable.
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1.6 Have the site EHS roles and responsibilities been defined, documented and communicated to appropriate employees? <br><br>Review job descriptions, EHS programs for definitions of roles and responsibilities. Interview employees to assess level of awareness and understanding. Confirm employees understand general site EHS rules and responsibilities (example: reporting unsafe conditions). Confirm employees understand responsibilities related to risk control programs such as lockout and confined space entry. Confirm employees assigned to special activities such as spill/medical/fire response understand their roles and responsibilities.
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1.7 Is there a process in place which assures EHS policies and procedures are followed? <br><br>Review disciplinary actions from past 12-24 months to determine frequency of EHS related actions being issued. Review accident investigation reports from past 12-24 months and cross reference with disciplinary actions to determine if action is taken when employee non-compliance is identified as a root cause.
Section 2.0 EHS Program Administration and Communications
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2.1 Does the facility have a Communications Board that is visible to all employees?<br><br>Review Communications Board for content and if it is up to date.
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2.2 Does the site have a system to recognize EHS achievements and promote participation in the EHS Program? <br><br>Have local management describe employee recognition programs. Interview employees and supervisory/management personnel to confirm interest and awareness. Have local management describe various ways employees can get involved in EHS activities and how they encourage participation.
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2.3. Is there a corrective and preventive action tracking system that is used to track and review with management environmental and safety items to resolution? Are the corrective actions effective and closed out in a timely manner?<br><br>Obtain most up to date corrective action list. Select a sample of action items noted on EHS accident/incident investigation reports, EHS inspection reports, storm water inspections, powered industrial truck inspection reports, etc., and confirm they have been entered on the central database, have an individual assigned to complete it, and target dates for completion. Corrective action closure rates (and lag times) should be reviewed to verify that management is holding supervisors accountable for closing out items.
Section 3.0 Risk Assessments and Hazard Control - Aspect Identification & Control
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3.1 Is there a process in place for completing risk assessments on all, or a clearly defined list of job tasks? Is the risk assessment method used appropriate for the severity and complexity of the hazards involved? Is each employee reviewing an SJP weekly? Have the SJPs been revised within the last year?<br><br><br>Review representative risk assessments from various jobs/tasks and evaluate for quality of hazard identification and associated risk control measures. Review a sample of the SJPs to evaluate the quality and assess whether the appropriate risk controls have been identified. Follow up on these risk assessments with employees to see if the risk control measures identified in the risk assessment are being applied. Look for evidence that legal requirements have been identified at some point in the development and implementation process. Check SJP revision dates. Check weekly employee review signoff sheet.
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3.2. Does the facility have a process in place that provides for regular inspection (s) performed by trained personnel to identify and correct unsafe/non-compliant conditions throughout the facility? This process must based on a schedule and performed by trained personnel. Is the inspection interval appropriate for the type of operation? Are items identified in the inspections corrected in a timely manner?<br><br><br>Review workplace inspection forms from the most recent 12 months. Take the most recent inspection findings and compare to audit team’s observations to assess completeness (quality) of inspections being performed. Randomly select six (6) corrective actions outlined in inspection reports, and determine time to closure . Documentation trail should continue through to formal closure of the item. Obtain training records to confirm employees completing inspections have received the appropriate training.
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3.3. Is each employee utilizing the card system to perform a quick hazard assessment prior to starting a job? Are Non-Routine Risk Assessment Forms being completed? Do employees know when to use the Non-Routine Risk Assessment process?<br><br>Check the cards that are being generated. Review the Non-Routine Risk Assessment forms.
Section 4.0 Legal and Other Requirements
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4.1 Has the site established, implemented and maintained a process to identify and understand changes in applicable EHS legal requirements, MTI requirements and customer requirements related to the site?<br><br>Have site personnel demonstrate ready access to current EHS laws (manuals, online services, email services, etc.). Confirm that resources being used are current and up to date. Review any third party compliance audits to confirm regulatory requirements are being met.
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4.2 Has the facility prepared, implemented, and maintained Standard Work and work instructions to ensure compliance with all legal, MTI and customer requirements and address significant EHS risk and environmental aspects identified from the risk assessments performed?<br><br>Look at the completed Standard Work and work instructions and observe how jobs are actually being performed to see that they match what's written and how effectively the site has controlled EHS related risk and complied with relevant regulations.
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4.3 Are all significant EHS incidents and required EHS data (as defined by the MTI Corporate EHS Department) reported on a timely basis to the Business Segment and Corporate EHS Departments through appropriate Business Segment process? <br><br>Interview EHS Coordinator and review local records and EHS incident investigation reports to identify possible gaps in reporting procedures. EHS coordinator should be aware of current requirements for reporting significant incidents. Interview employees to see if they know how to report incidents. Interview supervisors and managers to evaluate their understanding of the reporting process.
Section 5.0 EHS Training and Certification
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5.1 Is there evidence of an initial EHS induction program for all new and transferred employees? Is the training being provided in a timely fashion? <br><br>Review new hire induction process to assure required training is provided prior to starting job. Review training records to confirm compliance. Interview new and recently transferred employees to confirm training was provided. Obtain list of start dates of new employees and cross reference to training records.
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5.2 Have all the supervisory and management staff participated in EHS Training Courses that are specific to managing EHS requirements and program implementation? <br> <br>Review training records, interview supervisors and managers to assess effectiveness of training.
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5.3 Is there a training management system in place which allows for the effective management of the training programs and provides management with adequate information to identify and correct non compliance with training requirements <br> <br>Review system to assure all EHS training activities are included and that training needs are identified down to employee level.
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5.4 Site has created a team to implement the New Employee Training Standard
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5.5 Have you started training new employees to the new standard?
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5.6 Site has selected a trainer (s) for their site
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5.7 Number of employees with less than 1 year of service
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5.8 Total Number of tasks that need Job Breakdown sheets created
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5.9 Number of Job Breakdown sheets completed
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5.10 Total number of tasks that need competency checklists created
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5.11 Number of Competency Checklist completed
Section 6.0 Emergency Preparedness and Response
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6.1. Does the site have an Emergency Response Plan (or procedure) that has been implemented and maintained, and is it adequate for the type of emergencies that could occur at this facility? <br> <br>Assess completeness of program based on risk profile and geographical location of the site. Employee interviews should be used to determine if response procedures are clearly defined and adequate training is provided. Employee responses should be consistent to a high degree. Employee knowledge of evacuation routes and designated gathering areas will be evaluated through general interviews as well. Employees assigned with specific duties in the Emergency Response Plan should be interviewed to assess their understanding of their roles and responsibilities. Any documentation of general evacuation drills or emergency response team drills should be reviewed.
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Has an annual emergency drill been completed
Section 7.0 Supervisory EHS Incident Investigation
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7.1. Is the site following an EHS incident investigation process in place? Is it effective?
Section 8.0 Medical Surveillance
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8.1 Are medical exams up to date for all employees?<br><br><br><br><br><br>check the exam schedule against the exams completed.
Section 9.0 Compliance and Management System Audits
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9.1 Are all EHS programs audited at least every 2 years, or more frequently based on level of risk and/or significant change? The audit process shall include as a minimum a. Schedule of audits to be carried out. b. Review of procedures and documents to confirm it reflects current practice. c. Observations of work practices and employee interviews to confirm effectiveness of program and d. If applicable, assess compliance with local EHS regulations. <br> <br>Review results of self audits performed over the past 12 months and compare with findings developed during the audit to assess effectiveness. Review schedule to confirm all EHS Programs will be audited within a 2 year time frame.
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9.2 Does the site management team conduct regular reviews of the EHS Management System (at least annually)? *Results of both internal and external EHS Program audits. <br>• Results of evaluation of compliance with EHS, legal and other requirements. <br>• Communications from external parties, including complaints. <br>• EHS information and data including performance towards objectives, targets and goals. <br>• Status of corrective and preventive actions including follow-up actions from previous EMS reviews. <br> <br>Review results of most recent EHS MS review to confirm all audit elements were completed. Confirm that results of the audit were used in the development of EHS goals and objectives.
