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SOCIAL AUDIT CORRECTIVE ACTION PLAN (CAP)

Non-Compliance Finding (S) Recommended Corrective Action(S)


Monitoring & Documentation

Description Of Non Compliance 1 Legal requirement


No notice sent to the inspector of factories According to Section 52(1) of The
pertaining to the weekly rest day work Factories Act, 1948, No adult worker
No compensatory office provided to the shall be required or allowed to work in a
worker working on weekly off. factory on the first day of the week
(hereinfafter referred to as the said day),
unless -
(a) he has or will have a holiday for
whole day on one of the three days
immediately before or after the said
day, and
(b) the manager of the factory has,
before the said day or the substituted
day under clause (a) whichever is
earlier, -
(I) delivered a notice at the office of the
Inspector of his intention to require the
worker to work on the said day and of
the day which is to be substituted, and
(ii) Displayed a notice to that effect in
the factory
Recommended corrective action
Factory shall ensure to sent the notice
to the inspector of factories

Description Of Non Compliance 3 Legal Requirement


Factory has not provided payroll for the 7 According to Section 13A of the
security guards employed through Payment of Wages Act, 1936, every
Protector Security Services P. Limited so employer shall maintain such register
the compliance to these guards could not and records giving such particulars of
be verified for minimum wages, overtime persons employed by him, the work
hour's payment and benefits performed by them, the deduction made
from their wages, the receipts given by
them and such other particulars and in
such form as may be prescribed
Recommended Corrective action
Factory shall ensure to provide payroll
for the security guards too.

Description Of Non Compliance 1 Legal Requirement 1


Out of 20 Personnel files verified 2 files According to Schedule IB (I) (I) & (iv) The
were found without valid age proof records Industrial Employment ( Standing
Orders) Central Rules 1946iv) Record
of age, - (a) Every workman shall
indicate his exact date of birth to the
employer or the officefr authorised by
him in this behalf, at the time of entering
service of the estabnlishment. The
employer of the officer authorised by
him in this behalf may before the date of
birth of a workman is entered in his,
Child Labour

service card, require him to supply ;-


Recommended corrective action
factory shall ensure to provide the age
proof records for all the workers as required

Description Of Non Compliance 1 Legal Requirement 1


Chemical container (While petrol) were not According to rule 62 C (1) Tamil Nadu
labeled and no MSDS were not available Factoryu Rules 1950. The occupier of
for the same in the finishing section every factory carrying on a "hazardous
process" shall arrange to obtain or
develop information in the form of
Material Safety Date Sheet (MSDS) in
respect of every hazardous substance
or m,aterial handled in the manfacture,
transportation and stroage in the
factory. It shall be accessible upon
request to a worker for reference.
Safety
Recommended corrective action
Factory shall ensure tom label all the
chemicals stored in containers and shall
display the appropriate MSDS (Material
Health & Safety

Safety Datasheet) in all the areas of


storage and usage.

Description Of Non Compliance 2 Legal Requirement 2


Mock fire drill not conducted once in two According to rules 61 (12c) of the Tamil
months Nadu Factories Rules 1950, fire fighting
drills shall be held as often as
necessary and at least once in every
period of two months.
Recommended Corrective action
Factory shall ensure to conduct mock
fire drill once in 02 months

Legal Requirement 3
According to rule 35 of the Tamil Nadu
Description Of Non Compliance 3 Factories Rules 1950, the water
The factory has not conducted water test provided for drinking shall be suppliers -
for the drinking water provided at the (a) from a public water -supply system,
factory for workers or (b) from any other source approved
in writing by the Health Officer:
Recommended corrective action
Factory shall ensure to test the drinking
water for pot ability

Description Of Non Compliance 4 Legal Requirement 4


The factory has employed more than 250 According to Section 46 (1) of The
workers however no canteen facility Factories Act, 1948 The state
provided for the workers government may m,ake rules requiring
that in any secialised factory wherein
more than two hundred and fifty
workers are ordinarilly employed, a
canteen or canteens shall be provided
and maintained by the occupier for the
use of the workers
Recommended corrective action
Factory shall ensure to provide canteen
as per local law

Description Of Non Compliance 5 Legal Requirement


Broken needle records maintained for one As per the Client Requirement
& Safety (Domitories / Housing

section of factory properly but not for the


other section. Recommended corrective action
Factory shall ensure to maintain the broken
needle records for all sections
Health & Safety (Domitories / Housing

Descritption Of Non Compliance 1 Legal Requirement


It was noted factory is contributing According to Section 6 of The Employee's
Provident Fund on the basic and D.A Provident Fund and Miscellaneous Provision
bifurcation done by the factory itself, which Act, 1952. The contribution which shall be
is less than the minimum wages. paid by the employer to the fund shall be
Compensation & Benefits

12% of basic wages, dearness allowance


and retaining allowance if any
Recommended corrective action
Factory shall ensure to contriobute the
PF deductions according to the minimum
wage to be paid for the workers

Descritption Of Non Compliance 2 Legal Requirement


The ESI deduction is not rounded off to According to Rule 51 of The Employees
next one rupees as per the requirement State Insurance (central) Rules, 1950, The
Government of India Ministry of labour and
eimployment vide their notification
N.S-38912/1/2003-SS 1
dated 26.08.04 has amended Rule 51
of the ESI (central) Rules.1950 relating
to rounding of contribution to next
higher rupee. The factory shall follow
the same.
Recommended corrective action
Factory shall ensure to deduct ESI
contribution as per local law.

Descriptiopn Of Non Compliance 3 Legal Requirment


The factory has not contributed ESI for the As per Section 2 (22) of the Employees
overtime payment and attendance bonus State Insurance Act 1948, "Wages
provided to the workers "means all remuneration paid or
payable in cash to an employee, if the
terms of the contract of employment express
or implied were fulfilled and
includes any payment to an employee
in respect of any period of authorized
leave, lock-out, strike, which is not
illegal or layout, and other additional
remuneration, if any, paid at intervals
not exceeding two months, but does not
include--
a) any contribution paid by the employer
to any pension fund or provident fund or
under this Act
b) any travelling allowance or the value
of any travelling concession
c) any sum paid to the person employed
to defray special expenses entailed on him
by the nature of his employment or
Any gratuity payable on discharge
Recommended corrective action
The factory shall ensure to provide ESI
deduction for the overtime payment and
bonus also

Descriptiopn Of Non Compliance 3 Legal Requirment


According to Section 12 of the Minimum
The factory has paid less than minimum Wages Act, 1948, The employer shall pay
rate of wages prescribed by local law to every employee engaged in scheduled
currently for 33 workers. employment under him wages, at a rate not
less than the minimum rate of wages fixed by
such notification for that class of employees in
that employment without any deduction except
as may be authorized within such time and
subject to such conditions as may be
prescribed. According to the Minimum Wages
Notification for Employment in Tailoring Industry
G.O (2D) No.74, Labour and Employment,
dated 10/12/2004 Notification No. II (2) /
LE/98/2005, Published in T.N. Government
Gazette, Part II, Section 2, dated 02/02/2005 at
pages 58 59n Revised DA payable for the period
for the period from 01/04/2008 to 31/03/2009
shall be Rs532 per month. This calculates
INR 93.65 per day and INR 2435 per month as
per Zone-B for Helpers Category )

Recommended corrective action


Factory shall ensure to provide minimum rate of
wages to the workers as per requirment

Descriptiopn Of Non Compliance 1 Legal Requirment

No compensatory off provided for the weekly According to Section 52 (1) of The Factories Act,
rest day within 03 days for workers as well 1948, No adult woker shall be required or allowed
ork
as security guards to work in a factory on the first day of the week
(hereinafter referred to as the said day ) unless -
(a ) he has or will have a holiday for whole day on
one of the three days immediately before or after
the said day, and
(b) the manger of the factory has before the said
Hours of Work

day or the substituted day under clause


(a) whichever is earlier -
(I) delivered a notice at the office of the Inspector
of his intention to reuire the worker to work on the
said day and or the day which is to be
substituted, and (ii) Displayed a notice to that
effect in the factory

Recommended corrective action


Factory shall ensure to provide alternate day off
for the weekly rest day work

Descriptiopn Of Non Compliance 2 Legal Requirment 2


Overtime hours exceeding the legal limit for According to Section 64 (4) of The Factories Act,
workers as well as security guards 1948, in making rules under this section, the
State Government shall not exceed, except in
respect of exemption under clause (a) of
sub-section (2) the following limits of work
inclusive of overtime -
(I) the total number of hours of work in any day
shall not exceed ten (ii ) the spread over,
inclusive of intervals for rest, shall not exceed
twelve hours in any one day. (iii) the total
numbers of hours in a week including overtime
shall not exceed sixty (iv ) the total numbers of
hours of overtime shall not exceed fifty for any
one quarter
Recommended corrective action
Factory shall ensure to restrict the overtime
hours within the legal limit

Descriptiopn Of Non Compliance 3 Legal Requirment 3


As per the Section 24 and 25 of the water (prevention
NOC for Air and Water expired on. and Control of Pollution ) Act 1974 - The applicant
September 19.2007, but no renewal shall make an application along with prescribed fee for
obtained so for grant of fresh consent at least 120 days before the date
of expiry of this consent As per the Section 21 of the
Air (Prevention & Control of Pollution) Act 1981.-The
Environmental:

applicant shall make an application along with


prescribed fee for grant of fresh consent at least 120
Environmental:
days befor the date of expiry of this consent
Recommended corrective action
Factory shall ensure obtain the NOC from the consent
department
Sub-Contracting & Homework

Descriptiopn Of Non Compliance 1 Legal Requirment 1

Factory has doing sub - contracting work for As per the client requirement
washing and embroidery. For this no
approval from the Client. Recommended corrective action
Factory shall ensure to obtain approval from the client
before doing sub contracting
nded Corrective Action(S) Factory Proposed Action Step(S) Compliance Target Date(S)

52(1) of The
No adult worker
llowed to work in a
y of the week
to as the said day),

e a holiday for
he three days
r after the said

e factory has,
r the substituted
whichever is

at the office of the


ion to require the
e said day and of
e substituted, and
e to that effect in

ective action
to sent the notice
n 13A of the
Act, 1936, every
ain such register
ch particulars of
him, the work
he deduction made
receipts given by
particulars and in

rective action
to provide payroll

e IB (I) (I) & (iv) The


nt ( Standing
s 1946iv) Record

e of birth to the
efr authorised by
he time of entering
ishment. The
er authorised by
y before the date of
entered in his,
him to supply ;-
ective action
o provide the age
he workers as required

C (1) Tamil Nadu


The occupier of
g on a "hazardous
e to obtain or
n the form of
Sheet (MSDS) in
ardous substance
n the manfacture,

cessible upon
or reference.
ective action
tom label all the
ontainers and shall
te MSDS (Material
all the areas of

1 (12c) of the Tamil


s 1950, fire fighting

st once in every

rective action
to conduct mock

of the Tamil Nadu

shall be suppliers -
er -supply system,
source approved

ective action
to test the drinking

46 (1) of The

ke rules requiring
factory wherein

y employed, a
shall be provided
e occupier for the

ective action
to provide canteen

ective action
to maintain the broken
6 of The Employee's
Miscellaneous Provision
bution which shall be
to the fund shall be
dearness allowance

ective action
to contriobute the
ding to the minimum

1 of The Employees
tral) Rules, 1950, The
Ministry of labour and
ir notification

mended Rule 51
ules.1950 relating
ution to next
ctory shall follow

ective action
to deduct ESI

of the Employees
1948, "Wages

employee, if the
of employment express

t to an employee
od of authorized
, which is not
other additional
paid at intervals
onths, but does not

aid by the employer


or provident fund or

wance or the value

e person employed
enses entailed on him
mployment or
on discharge
ective action
ure to provide ESI
rtime payment and

n 12 of the Minimum
he employer shall pay
ngaged in scheduled
m wages, at a rate not
m rate of wages fixed by
hat class of employees in
out any deduction except
d within such time and
tions as may be
ng to the Minimum Wages
yment in Tailoring Industry
our and Employment,
tification No. II (2) /
ed in T.N. Government
on 2, dated 02/02/2005 at
ed DA payable for the period
1/04/2008 to 31/03/2009
onth. This calculates
nd INR 2435 per month as
rs Category )

ective action
to provide minimum rate of
as per requirment

n 52 (1) of The Factories Act,


shall be required or allowed
n the first day of the week
o as the said day ) unless -
e a holiday for whole day on
immediately before or after

factory has before the said


d day under clause

at the office of the Inspector


re the worker to work on the
ay which is to be
Displayed a notice to that

ective action
to provide alternate day off

n 64 (4) of The Factories Act,


under this section, the
all not exceed, except in
n under clause (a) of
ollowing limits of work

of hours of work in any day


(ii ) the spread over,
or rest, shall not exceed
ne day. (iii) the total
a week including overtime
(iv ) the total numbers of
all not exceed fifty for any

ective action
to restrict the overtime

4 and 25 of the water (prevention


ion ) Act 1974 - The applicant
ation along with prescribed fee for
t at least 120 days before the date
ent As per the Section 21 of the
ntrol of Pollution) Act 1981.-The
an application along with
nt of fresh consent at least 120
of expiry of this consent
ective action
obtain the NOC from the consent

ective action
to obtain approval from the client
Preliminary Remediation Reasons and Action Plans ( RRAP )

Remedial Steps
Clause No Audit Findings (to be Completed by factory)

1.1 Employee back roud checked but no policy in place.


The back round check conducted only for the packing
section workers only

1.4 Resignation policy in place but this is not copletely


provided information regarding security

1.5 Resignation policy in place but this is not completely


provided information regarding security

2.7 E,F & H System of security arrangement No CCTV /


No security alaram

2.9 No Security alaram

2.1 No electronic motion detector

2.13 No electronic system in place

2.14 No recorded secuirty tapes available

3.5 No procedure in place to handle the extended absences

3.6 No procedure in place to handle the extended absences

3.16 No written procedure to isolate the area to screen


incoming packages and mails

4.1 Factory has policy and procedures but this is not


covered certain requirments like termination procedures,
incoming package checking procedure etc

4.4 The procedure not available for unmanifested or


unapproved parts or components or raw materials

4.5 No written procedure but the goods movements are


controlled on incoming and out going But records are
maintained

4.6 No written procedure in place. And Finieshed products


found stored along with other un finished goods.

4.7 No written procedure but the containers and trailers


incoming or outgoings are controlled and monitored

4.14 No written procedure in place for container timely


movement

4.16 Procedure in place but not reviewed annually

4.18 Sub contracting facilities were not provided with adequate


supervision for security no records available

4.19 No random documented security assessment on regular


basis

4.22 No corrective action procedure maintained as no


assessment done on regular basis

5.3 Passowords not change periodically

6.1 No formal training procedure in this regard however factory


was trained for CT PAT once in the previous year

6.2 The training program could not be verified as the record


does not have the modules or procedural security.

6.3 The security training is not effective so that worker


understand fully about the requirment and importance

6.4 Internal conspiracies were not part of the training program

6.5 No documents or records of training which shows tranining


covers the objective of cargo or packed product security

6.6 Container security procedure is in place but not training


records available

6.7 No records showing training for unauthorized access

6.8 Incidengt reporting was not part of the security procedure

6.9 Proper training records were not maintained to verify this


requirement

6.1 No formal training records for information system security


principle

6.11 No mandatory training prescribed in the factory

6.12 No procedure in place to increase security based on the


employees report
6.13 No specific periodic security meeting for the employees in
place
Date
pleted by factory) completed
Preliminary Corrective Action Plan (CAP)

Corrective Action Plan


Clause no Audit Findings (to be completed by factory )

1.1.1 The factory has organization FACTORY ORGANISATION WITH


chart with different level but this DEFINED RESPONSIBILITY FOR EACH
is not complete. For example the INDIVIDUAL STAFF PREPARED AND
security in charge is not covered ENCLOSED HEREWITH AS ANNEXURE 1
in this chart. Responsibility is not
defined for individuals staff

1.2.1 Supplier list is available but no PROCEDURE FOR APPROVAL AND


procedure for approval and monitoring MONITORING SUPPLIER EVALUATION
program ALREADY EXISTS COPY ATTACHED
HEREWITH
1.2.2 No procedure in place for supplier SAME AS ABOVE
approval

1.4.1 No recall procedure in place PRODUCT RECALL PROCEDURE


FORMULATED NOW
1.4.2 No incident reporting and customer INCIDENT REPORTING AND CUSTOMER
notification procedure in place NOTIFICATION PROCEDURE
FORMULATED NOW
1.5.1 No customer complaint and investigation CUSTOMER COMPLAINT AND
system in place INVESTIGATION PROCEDURE
FORMULATED NOW
1.5.2 No customer complaint in place and no SAME AS ABOVE
records

1.6.1 No operation procedure in place for all WORK INSTRUCTIONS AND PROCEDURE
the activities so not assessed and IS ALREADY IN PLACE, COPY ENCLOSED
investigated for non-conformity against
procedure

1.6.2 No assessment and no root cause ASSESSMENT AND ROOT CAUSE


analyasis for NCs ANALYSIS OF NON CONFORMITIES ARE
DONE THRU FOLLOWING WORK INSTRUCTIONS
1.7.1 No formal training procedure for workers TRAINING POLICY EXISTS
and or contract actors and monitoring PROCEDURE FORMULATED NOW COPY
ENCLOSED
1.7.2 No training records available TRAINING RECORDS ARE FORMATTED
AND OBSERVED NOW
1.8.1 No formal procedure and instruction PROCEDURE AND INSTRUCTION FOR
available for product safety, legality and PRODUCT SAFETY, LEGALITY AND
quality QUALITY FORMULATED NOW
1.8.2 No formal documents in place for DOCUMENTS ARE IN PLACE FOR ALL
different activities ACTVITIES ARE IN PLACE AS PER
WORK INSTRUCTIONS
1.9.1 Document related to safety legality of RECORDS ARE FORMATTED
the relevant were not available AND OBSERVED NOW

1.9.2 No formal document control in place FORMAL DOCUMENT CONTROL IS IN


PLACE NOW
1.9.3 No documents related to legality safety RECORDS ARE FORMATTED
and quality maintained and handling AND OBSERVED NOW
procedure in place

1.9.4 Documents are not controlled so version DOCUMENTS ARE NOW CONTROLLED
not established AND VERSION ESTABLISHED

1.10.1 Quality records maintained but no time QUALITY RECORDS MAINTAINED WITH
sepcific as per customers TIME SPECIFIC AS PER CUSTOMERS
NOW
2.4.2 Maintenance program is not formal and MAINTENANACE PROGRAM IS NOW
adequate MDE FORMAL AND ADEQUATE

2.6.1 Workers were found wearing jewelery WEARING OF JEWELLRY IS A CUSTOM


and watches in all the sections FOR INDIAN WOMANHOOD. MEASURES
TAKEN NOW TO RESTRICT AT PACKING AREA
2.7.1 No pest control procedure in place PEST CONTROL PROCEDURE
currently FORMULATED NOW

2.7.3 No pest control activities in place so BEING NEW FACTORY BUILDING NO


this is not verifiable PEST CONTROL TOOK PLACE. BUT NOW
COMMENCED SAID ACTIVITY
2.8.1 No glass control in place GLASS CONTROL PROCEDURE
FORMULATED NOW
2.8.2 No glass control for glass window SAME AS ABOVE
breakages

2.8.3 No glass control policy and procedure SAME AS ABOVE


so no records available

2.9.1 MSDS was not provided for the stain MSDS NOW FORMULATED
remover white petrol

2.9.2 No persons authorization for chemical PERSONS ARE IDENTIFIED AND


handling AUTHORISED NOW FOR HANDLING

2.9.3 The chemical is not segregated and


stored at stain removing section

3.1.1 Factory has not conducted hazard


analysis system
3.1.2 No hazard analysis system in place for
foreign materials

3.3.1 Factory does not have procedure for


testing and analysis. Factory follows
client instruction for the testing and
inspections

3.4.1 No procedure in place for prevents


contamination of raw materials

3.4.2 Materials and products were not stored


at designated place

3.5.3 Metal detector is not installed

3.5.4 No metal detector so no operating


proceddure available

3.5.5 No metal detector so no operating


procedure and records available

3.5.6 No metal detector is installed so no


procedure to do in case of failure

3.7.1 No procedure in place for segregation


investigation and disposition of raw
materials

3.7.2 No procedure for NC product control and


no documentation in place

3.7.4 NC products are not handles as per


requirment

4.1.1 Factory has not identified the parameters


affecting the safety quality and legality

4.1.2 No flow diagram or check list in place

4.2.2 Incoming inspection is carried out but not


formally with any systematic manner with
specified procedure

4.2.3 No formal accept or reject criteria is defined


for raw material procedure

4.2.4 No insepection schedule or sampling plan


in place

4.3.2 No procedure in place for settings of critical


machines

4.3.3 No procedure for random sampling in use

4.3.5 No formal documented inspection procedure


No proper sample pla in place

4.3.6 No inspection criteria available in the factory


based on customer requirment

4.3.7 No formal inspection schedule and sampling


plan

4.4.1 Pre final inspection is carried out but nopt as


per the customer requirment

4.7.1 Weighing machine is callbrated but measuring


tape and fusing machines were not callbrated

4.7.2 Weighing machine is callbrated but measuring


tape and fusing machines were not callbrated

4.7.3 Weighing machine is callbrated but measuring


tape and fusing machines were not callbrated

4.7.4 Only weighing machine is callbrated

4.7.5 No records for callbration of measuring tape and


fusing machine
Date Completed

23.6.2008

23.6.2008

23.6.2008

25.6.2008

25.6.2008

25.6.2008

25.6.2008

25.6.2008

25.6.2008
CKING AREA

. BUT NOW