IMS REPORT 2020
MANAGEMENT REVIEW OF THE ENVIRONMENT-SAFETY MANAGEMENT SYSTEM YEAR 2020-2021
This Review considers the input data for the year 2020 from which considerations and possible opportunities for improvement emerge for the year 2021.
The first surveillance audit for the Safety Management System was conducted by Dekra on 24, 25 and 26 February 2020 (see Report I-K-1018518).
The environmental and safety audits, planned in the reporting period, were regularly carried out in 2020, while the monthly "environmental and safety tours" were suspended in March, April and May due to the contingent situation.
The audit of the PRD concerning the operational management of waste, shavings, yard cleaning and other activities, which are still indirectly inspected through the periodic "environmental tours", has been postponed to the early months of 2021.
The non-conformities emerged have been handled according to the procedures and will be examined in detail in the following points.
See also the attached table, which shows that the highest percentage of NCs is due to incorrect waste management and general untidiness; this is followed by the problem of inaccessible or incorrectly numbered fire extinguishers.
STATISTICS ON NON-CONFORMITIES (ACCIDENTS AND INJURIES FOR SMS)
A total of 4 non-conformities and 24 observations emerged from internal audits, and 21 nc + 1 obs. emerged from periodic environment-safety tours.
Most of these are related to incorrect waste management/sorting and non-compliance on fire extinguishers (obstructed access/incorrect numbering). See appropriate file.
The audit conducted by the certification body contains some recommendations to be considered as suggestions for improvement, which the company is currently working on.
During the year 2020, there were 7 accidents (only one of which required an intervention and was consequently managed under a RAC), which were included among non-conformities.
As to the other 6, one occurred to an employee on the way to work and five have been classified as accidental events which did not entailed any action.
In addition, one near-miss only was reported, which was handled as per procedure.
Two corrective actions were required to resolve the non-conformities found during the audits and the environment safety tours.
These actions are detailed in the relevant documents.
The first one, commenced on 26/10/2020, is in progress: it was decided to re-assess the MMC on the cylinder assembly stations and the expected completion date is April 2021.
The second one, which commenced on 29/12/2020, is obviously still in progress at the date of this Review.
OPPORTUNITIES FOR IMPROVEMENT
The Dekra audit revealed 16 opportunities for improvement that the company has assessed and completed, except for number 6, for which a dedicated PDCA was initiated.
STATE OF ACHIEVEMENT OF OBJECTIVES
Five improvement plans have been scheduled for the year 2020:
- “Sustainability” coffee vending machine project: successfully completed with the replacement of plastic cups and scoops in all vending machines installed; disposal methods have also been clarified and waste bins have been put in place.
- Analysis of conformity and related EC machinery documentation: at the date of the Review, the project has progressed by 70%. It is expected to be completed by mid-2021.
- Communication initiative entitled “Our green philosophy”: a section of Metal Work’s website has been dedicated to environmental issues (https://www.metalwork.it/pneumatic-components/green-philosophy-0016487.html), which is kept updated of new initiatives in real time.
- Healthcare prevention: the project underwent a change. At first it was planned to start with a prevention campaign directed to all workers (e.g. breast cancer prevention on 29/02/2020), but due to the contingent situation linked to the pandemic, it was decided to implement three screening campaigns with individual nasal/throat swabs and blood samples in order to contain Covid-19 infections.
- Installation of defibrillators and training of staff to use them: these devices have been purchased, but the courses were not held in 2020. It is planned to train staff from June 2021 onwards.
TRAINING AND COMMUNICATION
In 2020 in-house initial training has been provided for new recruits, covering both safety and environmental aspects.
Compulsory training on safety issues was provided for newly recruited workers and refreshing training courses were held for all employees.
PARTICIPATION AND CONSULTATION (SAFETY)- including ELEMENTS EMERGED DURING MEETINGS WITH THE WORKERS’ H&S REPRESENTATIVE (RLS)
The Prevention and Protection Service held a meeting on 15/01/2020, at which the chapters relating to the Risk Assessment Document (DVR), the accident trend, the PPEs and training were updated.
The requests for any clarifications or details presented by a H&S Representative on how to report accidents and the need to review the assessment of work-related stress in the MTG department were taken into consideration.
The documentation relating to this meeting is stored int he Safety Solution software.
As regards legislative measures, Metal Work has acknowledged the new statutory requirements and has modified the operations and procedures, as required.
The main stakeholders from which communications or requests may be received have been identified:
Municipality (including neighbourhood)
Public Healthcare Service
ENVIRONMENTAL PERFORMANCE DATA AND INDICATORS
All data and indicators in this section cover the whole of the country for the entire 2020.
No. of infringements=0; no. of accidents=0; limits exceeded on total number of analyses carried out: none; no. of complaints/reports from interested parties= 0.
The indicators identified as significant rare are shown in the attached diagrams.
COMMENTS ON DATA
Considerations on resource consumption, hazardous substances, packaging, waste production, emissions into the atmosphere, water effluents, soil and subsoil contamination, noise, landscape and visual impact are reported in the annual environmental review upgrade.
CHANGES IN SURROUNDING SITUATIONS AND LEGAL REQUIREMENTS
Metal Work has taken into consideration:
- IS communication management for cooling towers.
Legionella risk - Ge.T.Ra. telematic service (Cooling Tower management) issued by the Lombardy Governmental Authority to report the presence of wet cooling towers and evaporative condensers, in order to prevent and monitor environmental risks for legionella.
- Legislative Decree 116/2020 – transposition EU Directive 2018/851, amending Directive 2008/98/ECon waste and transposition of EU Directive 2018/852 , amending Directive 1994/62/EC on packaging and packaging waste.
Legislative Decree 101-2020 - … protection against hazards arising from exposure to ionising radiation.
Government Legislative Decree No. 44 of 1 June 2020 – transposition of EU Directive 2017/2398 of the European Parliament and European Council of 12 December 2017, amending Council Directive 2004/37/EC on the protection of workers from risks relating to exposure to carcinogens or mutagens at work: this amends Title IX, Chapter II, "Protection from carcinogens and mutagens", of Legislative Decree 81/2008 and its annexes:
- art. 242, paragraph 6: health surveillance of workers exposed to carcinogens and mutagens continues even after exposure and work have ceased, at the discretion of the competent doctor;
- Annex XLII (Substances, Mixtures and Processes): activities the expose workers to breathable crystalline silica have been included;-
- Annex XLIII (occupational exposure limit values): changing previous limits and adding new ones.
SIGNIFICANCE OF ENVIRONMENTAL ISSUES
The environmental issues initially identified are still considered valid, with the latest changes described below.
The objective set in 2013 was to eliminate the environmental issue relating to the emission into the atmosphere of VOCs with risk phrases R40, as a result of the decommissioning of the small metal washer that still used perchloroethylene as a degreasing substance (point E9).
In September 2013, two new emission points came into full operation: E11 (cutting, honing and grinding machine) and E12 (new metal washing machine). Point E11 generates emissions of dust and oil mist + PAHs; point E12 of n-butyl alcohol and 1-butoxy-2-propanol.
At the same time, VOS emissions (formerly E5 and E9) were eliminated: purchases of perchloroethylene in 2013 were zeroed.
In 2015, assembly departments were moved from the Via Segni site to the new Via Borsellino site; however, no environmental aspects have been added.
An initial environmental analysis dedicated to the Via Borsellino site was carried out at the beginning of 2016.
During 2016, as a result of the relocation of the assembly departments to the Via Borsellino building, the location of atmospheric emission points changed.
The environmental issues have not changed, however, as these are emissions of substances that were already present in the company and authorised.
As of 9 January 2017, there is a canteen service, provided by a catering company. However, this does not add any environmental issues: it is simply an increase in the amount of waste disposed of, as well as in the type (glass and organic fraction).
In 2017, there were no changes in processes that resulted in additions/changes in environmental issues and their significance.
In 2018, the data sheet relating to METAL WORK PRODUCT LIFE CYCLE ANALYSIS was only added (point 2A, with significance 1), which is an activity formalised following the transition to the ISO 14001:2015 reference standard.
In June 2019, the E10 emission point was modified (6 new machines for mechanical processing, with a consequent increase in extraction and replacement of the stack with one with a larger diameter to increase the flow rate); the analyses were carried out in September 2019.
In 2020, a computerised tomography system was introduced in the company, which allows measurements and checks to be carried out with X-ray scanning; it was assessed from the point of view of the health and safety of workers, but does not introduce any environmental issues.
Therefore, no environmental issues were added or changed in 2020.
Given the process of adapting the Environmental Management System to the 2015 revision of the ISO 14001 standard, a new Policy was issued in October 2017.
During 2018, in view of adapting the Occupational Health and Safety Management System to the UNI ISO 45001 standard, a new revision of the Policy was issued.
This contains the commitments that the Management had already expressed in the previous policy, to which the aspects related to the new standard have been added.
The policy is considered still valid.
It was documented in the "Context analysis, stakeholders and their expectations" report of November 2018 rev. 2; compared to the previous one, the part relating to health and safety issues was added, following the introduction of ISO 45001:2018.
It was updated in January 2021, obviously including the new data and numbers relating to the markets and a description of the situation created following the Covid-19 pandemic.
The section concerning environmental and operational risks is managed with the already existing analysis of environmental issues and assessment of their significance; management risks have been assessed and formalised in the "Risks of management processes" matrix, updated on 7 January 2021.
(common assessment matrix for all management systems)
Clearly, occupational health and safety risks are dealt with in the DVR; a matrix of risks relating to management processes has been formalised, as mentioned above.
VALIDITY AND EFFECTIVENESS OF DOCUMENTATION
As the result of the efforts made in 2018 to comply with UNI ISO 45001:2018, part of the documentation of the safety management system was reconsidered.
Some documents were modified, such as the Policy, the "Analysis of the context, stakeholders and their expectations", the "Risk analysis of management processes related to environment/safety".
The Management System Manual was modified accordingly.
No substantial changes to the documentation were required during 2020.
The scope is still the same and is considered still valid; only the production site in Via Borsellino was added in 2016.
The standard product life cycle, formalised in July 2017, is still considered valid; an in-depth analysis of the various stages - from sales to customer, installation, use, final disposal, and internal production and assembly at Metal Work - was added on 07/01/2021.
At the end of 2019, the company's CODE OF ETHICS was drawn up and published on the company website.
IMPROVEMENT PROJECTS FOR THE YEAR 2021
- Company car fleet consisting of electric or hybrid cars only
- Installation of double-glazed entrance doors to departments to minimise heat loss
- Purchase of weight reducers for the shipping department
- Specific MMC reduction interventions on all workstations