CAML policy

CAML policy is to ensure the responsible management of all its activities from product invention to use and beyond. Excellence in HSE performance is essential to this policy and CAML will:

  • be a responsible corporate member of society committed to continuous improvement in HSE
  • provide a safe and healthy work environment for all employees
  • minimize environmental impact and optimize the use of natural resources
  • meet or exceed regulations, legal requirements and international agreements
  • ensure HSE considerations are integrated into all activities
  • develop a culture which encourages employees to take personal responsibility for HSE
  • openly communicate HSE performance and enter into dialogue with interested parties
  • aim to eliminate all incidents and injuries

This policy has been adopted by the Board of Directors and applies to all employees and all activities. Compliance with the policy is mandatory.

These HSE Standards support the HSE Policy and apply throughout CAML. They outline the key steps that all managers need to take to ensure that the HSE Policy is successfully implemented.

Planning

1 Risk Management

2 Objectives and Improvement Plans

Preparing

3 Management and Resources

4 Training and Development

Implementing

5 Occupational Health

6 Safety 

7 Emergency Preparedness

Monitoring

8 Reporting

Communicating

9 Communication and Consultation

Planning

1 Risk Management

CAML manages its HSE risks to acceptable levels. The level of acceptable risk is determined by relevant laws, expectations of the company, our employees and the communities in which we operate.

Regular assessments must be conducted on health, safety, environment, and security risks, and steps taken to control them to an acceptable level.

Risk assessment

The risks associated with any new activity, or change to an existing activity must be assessed before it is undertaken. All risks must be reviewed at appropriate intervals.

Follow these key steps:

  • identify the hazards
  • identify who or what might be harmed and how
  • estimate the scale of each risk based on severity and likelihood
  • control risk to an acceptable level
  • regularly review risk assessments to ensure that they are still valid
  • look ahead – the full consequences of risk may take months or years to appear
  • make a written record of the findings

Those involved in risk assessment must have sufficient experience to make valid judgments. If in doubt seek advice from the relevant HSE professional.

Risk management

When making risk decisions:

  • act quickly when an unacceptable risk is recognized
  • consult the relevant experts
  • decide what precautions or controls need to be in place to reduce the risk to an acceptable level
  • ensure everyone involved knows how to implement and maintain the required precautions and controls
  • review decisions to ensure they remain valid use incident investigations to improve risk management assumptions and judgments

2 Objectives and Improvement Plans

It is essential that all HSE improvement activities are based on an assessment of the need, and undertaken in priority order.

Annually, all site/locations must set HSE objectives and prepare improvement plans. Progress towards the delivery of the objectives must be reviewed regularly. 

HSE objectives must be based on:

  • the business strategy and plans for the site/location concerned
  • CAML HSE Policy and Standards
  • relevant legal or regulatory requirements
  • key HSE issues identified locally or from appropriate benchmarking

Improvement plans must specify:

  • each target, and why it is important
  • how the targets and objectives will be delivered
  •  the key performance indicators to be measured
  • a timescale for delivery
  • the person responsible
  • the resources required

Preparing

3 Management and Resources

Accountability for HSE performance lies with managers, and is a key indicator of a manager’s performance.

Managers must implement the HSE Policy and Standards. In doing this the responsibility and authority of people undertaking activities on their behalf must be defined and appropriate resources provided.

The HSE professionals who provide direction and support to managers are accountable for the standard of their professional competence and advice. 

Managers must:

  • visibly demonstrate their commitment to the HSE Policy and Standards
  • create the right culture by demonstrating personal leadership and acting as role models
  • have appropriate skills, experience, and knowledge to successfully implement the HSE Policy and Standards
  • communicate the HSE Policy and Standards to all employees
  • provide strong leadership alignment with the HSE objectives to ensure activities under their control meet the HSE Policy and Standards
  • manage performance against clear operating standards
  • take decisive and appropriate action when operating standards are not met
  • ensure that HSE matters are considered in all relevant business decisions recognize and reward performance which positively reinforces the HSE Policy and Standards 

4 Training and Development 

Appropriate and regular training ensures that all employees understand the HSE Policy and Standards, and can carry out their work with due regard to health and safety and without causing damage to the environment.

The training needs of employees must be identified. Employees must receive appropriate HSE training and regular refresher training. Records of HSE training must be maintained.

Training must enable employees to:

  • understand the hazards and risks of the activities they undertake
  • consistently follow the required procedures both for normal operations and abnormal occurrences
  • continually improve the HSE culture of their workplace

Implementing

5 Occupational Health

Promoting and enhancing the health of employees is vital. Occupational Health is the activity aimed at the promotion of the physical, mental and social well­being of workers in all occupations by preventing ill health, managing health risks and adapting work to people.

Steps must be taken to prevent ill health, promote good health and address any changes to the health status of employees.

Preventing ill health

Health risks must be assessed and managed to prevent occupational illness.

Risks to consider include those arising from:

  • contact with hazardous chemicals
  • contact with biological agents
  • exposure to physical hazards (such as noise or radiation)
  • poor ergonomics
  • work related stress

If an assessment shows that any hazard poses an unacceptable risk, steps must be taken to reduce it immediately.

Promoting good health

The need for programs to promote employee health must be carefully considered, and where the need is demonstrated such programs should be developed.

Programs must be:

  • sensitive to local cultures
  • tailored to the needs of employees at each site/location

Addressing changes in health status

Employees must undergo a medical review if they become temporarily or permanently unable to do their normal work. Steps must be taken to allow them to come back to work when they are well enough, with either temporarily or permanently restricted work activities as appropriate.

6 Safety

CAML has the responsibility to ensure that people can undertake their work without risk of injury to themselves or others.

Steps must be taken to prevent incidents and injuries, improve safety performance, and to manage the consequences of safety incidents.

Preventing incidents and injuries

  • identify the hazards associated with work that could lead to incident or injury
  • carry out an assessment of the risks arising from these hazards
  • reduce any unacceptable risk immediately
  • put clear and appropriate procedures and controls in place to ensure the safe operation of each site/ location

Managing the consequences of safety incidents

  • ensure that adequate resources are available to deal with any reasonably foreseeable incident

Improving safety performance

  • timely and systematic review of safety performance
  • identify the root causes of incidents and take steps to stop them happening again
  • investigate safety incidents and share the learning

7 Emergency Preparedness

The likelihood of an emergency occurring is greatly reduced by good management practices. Preparation for an emergency is essential to minimize damage to people, assets, communities, the environment, and the reputation of CAML.

All reasonably foreseeable emergencies, including transport emergencies, must be identified.

Detailed plans and procedures for dealing with such emergencies must be developed at each site/ location. These plans must be regularly tested.

In advance of any emergency, managers at a regional, site/country level must:

  • establish a team to manage emergencies
  • identify individual roles and responsibilities for members of these teams
  • provide sufficient human and material resources for the team
  • be clear as to when and how to escalate between local teams

Monitoring

8 Reporting

Active reporting assists with reducing the frequency or recurrence of incidents. HSE data are used to track performance, monitor trends, identify issues and allocate resources. In addition, the most significant data are communicated to internal and external stakeholders.

All CAML sites/locations must have systems in place to enable the investigation and reporting of HSE incidents.

What to report

All HSE incidents relating to CAML employees or business activities must be reported and investigated at the site/location concerned. This includes driving on company business and transportation incidents.

Those incidents that are defined as being significant or severe must be reported centrally.

Details of each incident must be provided, including:

  • the type of incident
  • a description of the cause
  • corrective actions taken

The learning from the investigation of incidents must be shared as appropriate.

When to report

Severe incidents must be reported within 24 hours to the relevant line manager and/or HSE leader. These include:

  • incidents classified as emergencies
  • notification of prosecution, improvement orders or fines

All significant HSE incidents must be reported in the HSE performance reporting tool on a monthly basis.

9 Communication and Consultation

The sharing of information is essential in a learning organization to ensure people understand their roles and are engaged in what they are doing. HSE is an integral part of this and information regarding HSE objectives and performance needs to be widely communicated.

Systems must be established to enable effective communication with employees, contractors, suppliers, customers, local communities, neighbors and regulators.

The HSE Policy and Standards must be communicated to all staff.

Regulatory changes must be monitored and regulators engaged during the development and implementation of HSE related legislation.

There must be regular consultation and communication with staff to promote involvement in improvement programs, and provide updates on any relevant changes.

Employees must:

  • be informed about the hazards of materials, processes and activities with which they work or come into contact
  • understand the systems and requirements that are necessary for them to operate without harming themselves or the environment
  • be encouraged to participate in an open and constructive dialogue and culture to manage HSE, and to establish and communicate good practice

Managers must:

  • assess progress in meeting HSE Policy, Standards, objectives and targets
  • ensure that HSE performance is reported monthly

get approval for an annual HSE Letter of Assurance submission by the next level of management