Non Conformance Report (NCR

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Purpose : To define this procedure for planning, conducting and reporting of HSE Assessments carried out pertaining to OSHA Act 1994 Section 15, EQA Act 1974, and its regulations. The main objective will be to eliminate Hazard and reduce risk at work place. Scope: This procedure applies to HSE Non conformance audit/Inspection conducted by HSE Department or by HSE Committee or on site visit at Megasteel locations and in addition it may cover remote access surrounding Lion Steel complex that contains information that is relevant to the HSE related matters. NCR will be issued in order to eliminate the unsafe act or unsafe conditions. Responsibility: HSE Manager is responsible for overall implementation of this procedure. The HSE Department shall be responsible for ensuring that the audit is planned, managed and conducted in accordance with this procedure. Procedure: Schedule or non schedule HSE audit or inspection will be conducted by HSE personnel and Safety Committee. When there are unsafe acts or unsafe conditions been found, NCR will be raised to the audited area and person in charge and to the Department Head of Department, HOD.

Section 1 - To describe the non conformance issue and explanations of the finding during an audit or inspections. The Risk Classification will be determined by Major, Minor and Observation finding and interpreted as per below. y Major ± Where when the risk could lead to human fatality, serious bodily injury, permanent disability, loss from property/environmental damage or if more than 3 minor risks will lead to a major and or not complying to OSHA 1994 and FMA 1967 legislation and EQA 1994 Act and Regulations. Minor ± Where the Risk is not as defined in major, and not complying with internal safe work practices could lead to unsafe act and unsafe condition. Observation ± Where the risk can be instantaneously closed or improve in the terms of safe work practices.

y

y

Section 2 - The receiver to identify the possible root causes of the NCR finding and acknowledge the Hazard in the area. The receiver will take ³immediate corrective action´ for short term measure. While the long term permanent corrective measure will be plan and complete with in the targeted Completion date. Receiver will ensure ³Person(s) Responsible for the Corrective Action´ (if involve more people to conduct corrective action. This may take the form of specific control measures and should take into account the hierarchy of controls. HOD and Manager needs to be informed and made aware of the NCR. Sections 3 - The HSE Department to evaluate the NCR whether improvement has been met such as or eliminate or reduce the risk in the area. Once the NCR has been evaluated it can be closed and reviewed in the future.

equipment or materials Congestion or restricted action Hazardous environment conditions gasses.Guideline of Non Conformance Code. smokes.CODING OF BASIC CAUSES: PERSONAL FACTORS Inadequate capability Lack of knowledge Lack of skill Stress Improper motivation Others (Please specify) JOB FACTORS Inadequate work standards Inadequate leadership / supervision Inadequate engineering Inadequate purchasing Inadequate maintenance Inadequate tools/ equipment Inadequate work standards Wear and tear Abuse and misuse Others (Please specify) TYPE OF CONTACT Stuck against Stuck by Caught in Caught on Caught between Slip CONTACT WITH Radiation Caustics Electricity Heat Cold Noise Toxic or noxious Substances Overexertion Fall to below Fall on same level . fumes. dusts. A. CODING OF IMMEDIATE CAUSES. CHECK ALL APPLICABLE SUBSTANDARD ACTIONS Operating equipment without authority Failure to warn Failure to secure Operating at improper speed Making safety device inoperable Removing safe devices Using defective equipment Failure to use personal protective equipment properly Improper placement Improper loading Improper lifting Improper position for tank Servicing equipment in operation horseplay Under the influence of alcohol and / other drugs Others (Please specify) SUBSTANDARD CONDITIONS Inadequate guards or barriers Inadequate or improper protective equipment Defective tools. vapor Noise exposures Radiation exposures High or low temperature exposures Inadequate or excess illumination Inadequate ventilation Others (Please specify) B.

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