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Safety and Health Management System

5-STAR
Procedure No: OHS-PR-02-04
Legal and Other Requirements
ISO 45001 Clause 6 (6.1.3)

Responsibility
Detail Name Signature Designation

Executive Director,
Recommended by: Khalaf Manahi ALRashdan
Industrial Security

Approved by: Khaled Saad ALRashed General Services Senior VP

Adoption by: Fahad Hussain ALSudairi CEO (Acting)

Revision Responsible Description Date

0 Safety Development Initial Issue of document 20/12/2018

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TABLE OF CONTENTS

1 PURPOSE...................................................................................................................3
2 Scope........................................................................................................................3
3 Definition and Acronyms...........................................................................................3
4 Responsibilities..........................................................................................................4
5 Implementation Requirements..…..………………………………………………………...6
5.1 legal Register and Library..……………....………...........................................................6
5.2 Communication and Training………………………………………………………………….6
5.3 Audits…………………………………………....……..………………………………………..7
5.4 Records.………………………………………………………………..……..…………………8
5.5 Permits, Licenses, Exemptions or Concessions.…………………..……………………….8
5.6 Legal and Delegation / Assignment appointments………………………………………….8
6 Performance Requirements........................................................................................9
6.1 OHS-STD-02-04 Legal and Other Requirements....…………………………..…………...9
7 Reference Documents..…………………………………………………………………...9
8 Appendices...……............................................................................................................9

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2 Purpose

To ensure that a formal process is in place to identify and have access to all up-to-date
Health and Safety requirements (laws, permits, licenses, covenants, project approval
conditions etc.) pertaining to the activities of the Organization and its Business Line
Entities operations, and to assess compliance with those legal requirements .

3 Scope

This procedure applies to all Saudi Electricity Company business line Entities and the work
performed by its employees, contractors, suppliers and community who may be affected by
SEC activities or who undertake activities on behalf of SEC.

This procedure is to be read in conjunction with the relevant Saudi Electricity Company
corporate OHS policy, manual and standards.

The words “shall” and “must” in this procedure indicate mandatory requirements. The word
“should” indicates a preferred approach.

4 Definition and Acronyms

OHS: Occupational Health and Safety.

OHS Management System (OHSMS): Those parts of the overall management system
(OHSMS) that facilitates the management of OHS risks associated with the business of
Saudi Electricity Company. It includes the organizational structure, planning activities,
responsibilities, practices, procedures, processes and resources for developing,
implementing, achieving, conforming with, reviewing and maintaining the OHS Policy.
Legal Requirements: Requirements resulting from laws, regulations, judicial orders,
administrative orders, consent decrees, municipal ordinances, etc. Identifying "legal"
requirements means making sure the organization knows which governing bodies
(national, local) have authority as related to their activities and the full extent of what
requirements apply.
Organization: In the context of SEC and for purposes of complying with this OHSMS, it
refers to its Business Line Entities, Sectors, Departments and Divisions which include, but
not limited to (facilities, plants, operations, projects and sites).
Other Requirements: Includes both Corporate requirements and any other requirements
to which the organization has committed to or voluntarily subscribed, e.g., ISO
45001:2016, ISO14001:2015, ISO 9001: 2015. Historic mandated or voluntary
commitments must be included unless the organization has made appropriate documented
notification that they are no longer committing.
SEC: Saudi Electricity Company.
Stakeholders: Person or persons significantly impacted or potentially impacted by the
organization’s operations. These may include employees, stockholders, customers,
neighbours, emergency responders, other industries, competitors, commercial partners,
the public at large, non-governmental organizations (NGO's), government authorities and

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regulators, and anyone else with a significant personal interest in the organization’s
operations.

4 Responsibilities

4.1 Legal Affairs Department

The Legal Affairs Department shall:

 Develop and implementing a processes for identifying, accessing, monitoring,

and updating all relevant international, national, local and provincial statutory
obligations and other OHS requirements that may be applicable to the
Organization and its Business.
 Ensure a formal Company OHS Legal Register is collated, maintained and
available to the organization on-line through the company web-site.
 Implement a method to communicate OHS legal and other requirements
throughout the organization and to other stakeholders including communication
of revisions and amendments that may affect OHS compliance status.
 Assess the potential consequences of OHS legal and other requirements on the
organization’s aspects and to ensure potentially significant consequences are
included in the organization’s objectives and targets planning process.
 Liaise with government authorities regarding regulatory requirements as
required.

4.2 Business Line Leaders

The business line leader shall:

 Ensure each department’s maintain processes for identifying, accessing,

monitoring, and updating all relevant national, provincial and local statutory
obligations and requirements that may be applicable to that department.
 Ensure a process be maintained to ensure that all OHS regulatory requirements
are met, and designated persons are appointed to be responsible for monitoring
compliance and reporting.
 Ensure that formal OHS Legal Register be collated and maintained for each
department.
 Ensure that formal reviews and updates to each department’s Legal Register be
conducted at least annually, or when major changes occur.

4.3 Occupational health and safety (OHS) Coordinator

The OHS Coordinator should:

 Ensure relevant information on legal and regulatory a requirements is provided
to management, employees and stakeholders as required through induction and
ongoing training;

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 Keep up to date with changes to the legal and regulatory requirements, assess
any impact of those changes to the department and advise management and
stakeholders accordingly (including the OHS Committee);
 Facilitate changes in practice and procedures where required to comply with
legal and regulatory requirements;
 Facilitate workplace OHS inspections and audits to monitor compliance with
Regulatory requirements, and identify opportunities for improvement;
 Provide a system where documentation is maintained and provides evidence
that workplace OHS systems and procedures are implemented in accordance
with legal and regulatory requirements;
 Maintain records, or ensure that records are being maintained, as required by
Regulatory requirements.

4.4 Managers and Supervisors

Managers and Supervisors shall:

 Ensure legal and regulatory requirements and changes are communicated to
employees within their areas of responsibility.
 Ensure that employees within their areas of responsibility attend training and
instruction on regulatory requirements relevant to their workplace.
 Provide information to the OHS coordinator and Team to ensure that the records
that are required are kept and current.
 Assist in the issue resolution process were required.
 Create and maintain records, as required by the legal and regulatory
requirements.

4.5 Employees and Contractors

Employees and Contractors shall:
 Implement any instruction that is given to comply with a legal and regulatory
requirement.
 Attend training that is provided that is related to legal and regulatory
requirements relevant to their workplace.
 Comply with all the organizations workplace occupational health and safety
procedures which are designed to comply with legal and regulatory
requirements.

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5 Implementation Requirements

To ensure compliance to legal and regulatory requirements and other requirements that
the organization and its business lines subscribe to, e.g. ISO 45001:2017 standard, two
mechanisms shall be implemented, namely a legal register and library

5.1 legal Register and Library

5.1.1 The Legal Affairs department is responsible to compile and maintain a legal
resister and database on the company Website that shall be accessible to all
employees and updated annually.

5.1.2 In the event of any form of legal or other requirement impacting the organization,
the Legal Affairs will communicate the same as per the company communication
plan in line with the requirements of the OHS-PR-02-02 Communication and
Consultation Procedure.

5.1.3 A documented OHS legal and regulatory and other requirements identification
and assessment process shall be conducted by each department to collate and
maintain a formal OHS Legal Register.

5.1.4 A OHS legal library shall be established and contain the following:

 national legislation;
 provincial legislation;
 local by-laws;
 stakeholder requirements;
 industry codes of practice; and
 non-regulatory guidelines.

5.1.5 As new or amended legislation is promulgated and the library shall be

continuously updated and maintained.

5.1.6 When legislation changes the Librarian or OHS coordinator should receive the OHS
legal updates from the Legal Affairs Web-site. Subsequent to updating the legal
library the OHS coordinator is responsible to extract the relevant information and
updates the department or project legal register accordingly.

5.1.7 The changes to legislation are then communicated to the manager who in turn
assesses the level of applicability in his area of responsibility and identify and
implements the required changes to operational procedures.

5.2 Communication and Training

5.2.1 Communication
 Make regulatory requirements and changes a standing agenda item on
Departmental OHS Committee meeting agendas.

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 Ensure regulatory requirements and changes are communicated to

employees, contractors and other stakeholders within their areas of
responsibility.
 Provide information to the OHS Representatives and Safety Teams to
ensure that scheduled activities that are required to be carried out under the
Regulatory requirements are completed.
 Provide information to the OHS Representatives and Safety Teams to
ensure that the records that are required to be kept are current.
 Facilitate changes in practice and procedures where required to comply with
Regulatory requirements.

5.2.2 Training
 SEC Training Department in consultation with the Legal Affairs Department
together review the workplace OHS and training requirements for employees
and stakeholders to ensure that regulatory requirements are understood.
 SEC Training Department ensure relevant information on regulatory
requirements is provided to employees and stakeholders as required through
induction and ongoing training.
 Ensure that employees and contractors within their areas of responsibility
attend training and instruction on regulatory requirements relevant to their
workplace.
 Changes to legal requirements may result in the use of workshops to
communicate the changes to all relevant employees.

5.3 Audits
OHS regulatory and legal compliance assessment (audits) shall be done on an annual
basis, based on the information in the legal registers.

5.3.1 During audits the following will be formally assessed:

 Completeness of the legal library information;
 Completeness of the registers;
 Compliance to the requirements identified in the registers; and
 Level of performance regarding the execution of control measures.

5.3.2 Documented findings from the audits can result in:

 Corrections to the information in the library;
 Corrections to the information in the register;
 Corrections to operational documentation;
 Implementation of additional control measures; or
 Compilation of management plans to implement actions to ensure
compliance where non-compliance to legislation or control measures is
identified.

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5.3.3 The areas of non-compliance can be addressed in incident / non-conformance

reporting and/ or management plans in the risk management registers.
5.3.4 Management shall facilitate internal workplace OHS inspections and audits to
monitor compliance with Regulatory requirements, and identify opportunities for
improvement.
5.3.5 OHS regulatory and legal compliance shall be annually reviewed and validated
by management during the Management Review process.

5.4 Records
5.4.1 The results of the OHS regulatory, legal and other identification and assessment
shall be documented as per the requirements of the procedure OHS-PR-02-08
Document Control.

5.5 Permits, Licenses, Exemptions or Concessions

5.5.1 Management shall develop, implement, maintain and document corporate

and/or business line OHS external communications procedures which, at a
minimum, require: Should applications for exemptions, concessions,
instructions, licenses or permits be required, the responsible manager will draft
the application to the relevant Government Department for signature by the
business line manager. The manager is responsible to ensure that a new permit,
licence, exemption or concession is obtained prior to the expiry of the current
document.
5.5.2 Expiry dates are documented in the document management system / register.
All communication must be handled in accordance with the procedure OHS-PR-
02-02 Communication and Consultation.

5.1 Legal and Delegation / Assignment appointments

5.6.1 Legal appointments and Delegation / Assignment shall be done in accordance

with legal requirements and corporate procedure OHS-PR-02-01 Leadership,
Responsibility and Accountability at all the relevant levels. The original legal and
Delegation / Assignment appointment letters are kept by the managers whilst
copies are kept by the appointee. This is also applicable to business partners
(contractors) and their specific legal appointments.

6 Performance Requirements
6.1 OHS Standard 04 - Legal and Other Requirements.

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7 Reference Documents
7.1 OHS-MAN-02-01-2017
7.2 OHS-PR-02-01 Leadership, Responsibility and Accountability.
7.3 OHS-PR-02-02 Communication and Consultation.
7.4 OHS-PR-02-07 Document Control procedure.
7.5 ISO 45001:2017.
7.6 Legal Register.
7.7 Legal Library

8 Appendices
None

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