Emsp 7 Legal Compliance Evaluation
Emsp 7 Legal Compliance Evaluation
Emsp 7 Legal Compliance Evaluation
EVALUATION.
DATE ISSUED: 31-12-2018
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1. PURPOSE
To establish and maintain a documented procedure for periodically identifying, auditing and
evaluating compliance with applicable environmental legislation, codes of practices
regulations, rules, government policies and other requirements applicable to Delta
Beverages-Kwekwe Maltings identified environmental aspects and impacts .
2. SCOPE
This procedure is applicable to Delta Beverages Kwekwe Maltings Environmental
Management System operations.
3. RESPONSIBILITIES
All HODs are responsible for ensuring compliance to this procedure in their departments
The QC Manager has overall accountability for ensuring that implementation of this
procedure is done properly. Further it is the Quality Manager’s responsibility:
3.1 To ensure that HOD’s and relevant personnel in their departments are Aware of the
requirements of any new relevant legislation by making a copy of the law available,
emphasizing the key sections and the steps to be taken to attain compliance. Where
necessary the Quality Control Manager paraphrases the relevant key sections for ease
of interpretation.
3.2 To ensure, in consultation with the Plant Manager, that relevant senior managers
contribute to the development of policies, legislation and regulations that affect Kwekwe
Maltings as per the company’s Environmental and Safety Policies.
3.3 To communicate non-compliance(s), regulatory or otherwise, if need be, to any outside
body including government or local authority to complement the Kwekwe Maltings Plant
Managers communication responsibilities.
3.4 To keep an updated legal compliance register (Environmental Performance
Requirements Manual) and documented corrective action programmes.
3.5 To ensure that heads of department (Hod’s) timeously carry out and document self-
assessments of their compliance with environmental laws, regulations, rules and
government policies and any other requirements of the Kwekwe Maltings Environmental
Management Systems (EMS).
3.6 To ensure that HOD`s report non – compliances, regulatory or otherwise, to the Quality
Control Manager at their earliest opportunity. To ensure that HOD`s undertake follow ups
on corrective actions on non-compliance(s), regulatory or otherwise, as expeditiously as
possible and to document all corrective actions taken.
TITLE : LEGAL COMPLIANCE EVALUATION. DOCUMENT NO: NO: EMS P-07
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3.7 To ensure liaison between the HOD`s and the SHE Department where need arises.
4 DEFINITIONS
Nil
5 ACTIVITY DESCRIPTION
5.1 Planning
The Quality Control Manager obtains the annual publications of the Index to the Legislation
in force in Zimbabwe to update the legal register and ensures that the government gazette
which carries new laws or amendments to existing legislation, or repeals is circulated
to all heads of department by the Executive Secretary. The Quality Control Manager causes
the withdrawal of repealed laws from circulation.
5. 2 The Quality Control Manager develops an annual environmental audit schedule for
Kwekwe Maltings at the onset of the year. The results of the audits are documented with
timed improvement plans.
5.3 The Quality Control Manager develops a schedule for external environmental auditors to
audit Kwekwe Maltings at least once every three years unless otherwise imposed by other
requirements. The results of the audits are documented with a timed environmental
improvement plan.
5.4 A standing legal permission is available in the law for the government or local authority
officers to audit or inspect Kwekwe Maltings at any reasonable time for legal compliance.
Every effort will be applied to promptly comply with the results of such audit or inspection
whether documented or not.
5.5 Any deferment or postponement of a planned safety, health and environmental audit
should be agreed to by the Quality Control Manager and the alternative date set as close as
possible to the original audit date but no later than 10 days of the original date.
5.6 A review of the relevant laws, regulatory records, measuring and calibration records,
operating instructions, procedures or standards operating, shall take place before and after
each audit and / inspection.
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5.7 For self-audits and inspections, the HOD or a section head in the department or both the
HOD and the section head and any other person(s) he or she may wish to have in the audit
team, will inspect or audit all areas of the department, assessing the environment for
chemical and oil spills, air and land emissions, housekeeping and waste management,
observing operating conditions, noise and interviewing workers in the areas being audited or
inspected and recording all the findings regardless of whether or not the enabling law is
known.
5. 8 For half yearly environmental audits and inspections, the Quality Control Manager puts
together an audit team that includes trained internal auditors and heads of sections or
departments being audited as guides. The audit begins with a pre- audit meeting in the
office of the HOD whose department is to be audited or in any other suitable office to discuss
the audit plan.
The audit covers all matters raised in 5. 6 above including licences, permits and any other
matter and shall end with a close out meeting in which results of the audit are discussed
before the report is written so that corrective actions may commence immediately where
necessary.
5. 9 For annual environmental audits and inspections, the Kwekwe Maltings internal auditors
carry out the audit guided by the Internal audit procedure and the legal register. The audit
commences with a pre- audit meeting with senior management and report back meetings
can also be arranged during the audit. The audit ends with a close out meeting with senior
management in which the preliminary results are discussed so that corrective action may be
immediately where necessary. The Quality Control Manager produces the audit report and
an annual environmental improvement plan based on the audit findings.
Corrective Action
5.10 The HOD promptly initiates corrective action to resolve any regulatory non-compliance
if such a finding is made in the audit or inspection.
5.11 The HOD conducts a follow up surveillance of the corrective measures taken. If a
corrective plan was developed, a finding of closure occurs immediately upon verification of
the completion of the corrective action.
A copy of the closure report is submitted to the HOD and the Quality Control Manager.
5.12 The distribution of the monthly and annual environmental audit and inspection reports
includes members of the audit team, all heads of department and the Plant Manager
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.6 RECORDS
7 REFERENCE
7.1 Environmental Policy
7.2 Kwekwe Maltings EMS Manual clauses 4.2, 4.3, 4.5 and 4.6,
7.3 Procedure EMS P1 Aspects Identification Aspects and Rating their significance.