TATA Realty

(Tata Housing Development Company Limited)

Project Management Group

SOP for Consultation and Participation of workers

Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1

TATA Realty
Name Designation Signature Date

Prepared By Devesh Ghuley CO DGM- EHS 10-01-2022

Reviewed and 10-01-2022
Virendra Singh CO AVP- EHS
Recommended By
Head – QAQC 10-01-2022
Approved By Vijayakumar
& EHS

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1

1
 Disclaimer

Issued as: CONTROLLED COPY / UNCONTROLLED COPY for information purpose (Appropriate status
to be highlighted) this document is the property of and Tata Realty (TRIL & Tata Housing) and their
subsidiaries. Print out of this plan shall be uncontrolled copy unless its controlled/ master copy seal.
Unauthorized photocopy or electronic copy either partly or fully is prohibited. Authorized controlled
copy of this document is available at Corporate EHS Team and shall be issued by them.

Revision History

Section Ref in
S. N which changes Description of revisions done Rev. No
carried out
1 NA Original Issue R1

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1

2
 SOP for Consultation and Participation of workers
Tata Realty has established, implemented and maintained a procedures for consultation and
participation of workers at all applicable levels and functions, and, where they exist, workers’
representatives, in the development, planning, implementation, performance evaluation and actions for
improvement of the EHS management system.

Tata Realty has:

a) provided mechanisms, time, training and resources necessary for consultation and participation;
b) provided timely access to clear, understandable and relevant information about the EHS
management
system;
c) determined and removing obstacles or barriers to participation and minimize those that cannot be
removed;
d) emphasized the consultation of staff (non-managerial workers).
e) emphasize the participation of staff (non-managerial workers).

The consultation and participation of workers, and, where they exist, workers’ representatives, can be
key factors of success for an EHS management system and is being encouraged through this established
processes. Consultation implies a two-way communication involving dialogue and exchanges.
Consultation involves the timely provision of the information necessary for workers, and, where they
exist, workers’ representatives, to give informed feedback to be considered by the organization before
making a decision.
Participation enables workers to contribute to decision-making processes on EHS performance
measures and proposed changes.
Feedback on the EHS management system is dependent upon worker participation. The organization
ensures workers at all levels are encouraged to report hazardous situations, so that preventive
measures can be put in place and corrective action taken.
Efforts is being made to make more effective the suggestions if workers do not fear the threat of
dismissal, disciplinary action or other such reprisals when making them.
Organisation has established this procedure to ensure effective participation and consultation in the
EHS management system by workers at all levels and functions of Organisation by:
a) Provide mechanisms, time, training and resources necessary for consultation and participation;
 Project EHS Committee: named as “Safety Committee” at project level shall be formed represented
by equal number of representatives of management (organisation & Contractor) and building
workers and representatives from contractor to ensure participation of workers as per the
provisions of The Building and Other Construction Workers (Regulations of Employment &
Conditions of Service) Act 1996 and respective state rules. Participation by workmen and employee
to discuss EHS matter and consultation also take place. Top down communication: Points decided is
implemented at site. Bottom up communication: Points raised from workmen and/ or their
representatives or employees are being discussed. MOM is available at respective site.
The agenda and minutes of the meeting shall be prepared and circulated/ communicated to all the
concerned. The respective department in charge within reasonable time limits shall comply with the
decision and recommendation of the Safety Committee. The EHS Committee shall meet at least
once in a month. Worker representation can be a mechanism for consultation and participation.
 Corporate EHS Management Review Meeting Committee: It is committee of top management to
develop the strategy for the company and review the performance. Top down communication:
Points decided is implemented across regions/ sites. Bottom up communication: Points from audits,
points raised by regional safety implementation committee (REHSIC) meeting, etc. being discussed.
MOM is available with EHS team.

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1

3
 Regional EHS Management Review Meeting Committee: Participation by projects head, regional
head and EHS coordinator for review and implementation for EHS MS at respective regional level.
Top down communication: Points decided is implemented across regional sites. Bottom up
communication: Points from audits, points raised by project safety committee meetings, etc. being
discussed. MOM is available with secretary of this committee (nominated EHS coordinator of one of
regional site).
 Project Review Meeting (PRM): On monthly basis, EHS activity, audit result, incidents details,
initiatives and performance (collated based on monthly EHS performance), etc. are being
communicated from CO EHS team to all key management team (project heads, corporate head,
regional head, EHS coordinator and CO EHS team) from all sites. It is a discussion forum where key
issued are discussed. Technology aids helps to connect all sites.
 Town Hall meeting: Annually this meeting organised by CO HR team and addressed by MD and CEO
to communicate company’s performance, vision, mission, objectives, issues/ challenges, EHS focus
area, etc. It is a two way communication between all employees and top management. Technology
aids helps to connect all sites.
 EHS Connect: Video conferencing meet with CO EHS team and Project EHS coordinator:
Participation and consultation with site EHS coordinator on EHS issues.
 Top management site visit: During site visit/ discussion during meeting senior management interact
with employee and workers where consult EHS matter and ask for input for improvements.
 Project EHS walk through: Project team conduct site visit jointly with contractor/ employees/
workmen/ their representatives and interact/ consultation with workmen too on EHS issue.
 Near miss/ EHS Observation/Suggestion/Incident Reporting Box: Suggestion can be given by
employee, contractor, workmen, visitor, supplier, etc. through written/
verbal. Suggestion can be written in TMT-021. Those workmen cannot
write, site engg/ EHS coordinator or other can write suggestion on his/
her behalf in prescribed form. It is recommended that appropriate reward
shall be provided to suitable suggestion/ observation provider at
appropriate platform. EHS coordinator shall keep suggestion box at
different places at sites (for example at entrance/ security gate, office of
client/ contractor/ sub-contractor/ store/ OHC/ Induction room/ camp,
etc.). Implementable minor suggestions can be solved at the level of EHS coordinator. Suggestion
involving significant cost that shall be escalate and discussed with Project Head. Final decision shall
be taken by Project Head.
 Meeting with contractor pre award, post award and during execution: Informal meeting take place
with contractor/ supplier as necessary to communicate EHS expectation and provide platform to
participate in discussion EHS integration as a part of work/ service provide and involve consultation
too.
 Bottom up communication: This initiatives (in which inputs taken from shop floor/ other
stakeholders and communicated to CO EHS team) may be done by CO EHS team. CO EHS team may
instruct to all EHS coordinators to gather EHS input on Policy and EHS MS from all stakeholders
(contractor, supplier, contractor, workmen, neighbours, etc.) through verbal/ documented in formal
or informal way. Site team shall share their inputs through email/ verbal (preferred)
communication. Besides this, CO EHS team can gather inputs from site while their visit. These input
shall be helpful to upgrade/ revise the EHS MS. At site level: consultation being done at site level
while executing the respective EHS process whether in formal/ informal way of discussion in Project
EHS meeting/ on site discussion etc.
Resources: Necessary resources being provided to carry out participation and consultation for example
meeting room, projector, communication means (email/ phone etc.) and EHS man power, EHS
suggestion box with stationery.

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1

4
Feedback/ inputs from workers/ their representatives are taken through in writing/ preferably verbally
in a formal/ informal way as and when required. Besides this, it may be discussed in safety committee
meeting. As required, translation shall be done.
Time: Sufficient time being provided to raise point by each and individual to discuss on EHS matter.
Every point even of trivial also being respect and welcomed.
b) Provide timely access to clear, understandable and relevant information about the EHS
management system:
 Posters: Relevant EHS posters displayed to communicate hazard/ risk and control required at
requisite places.
 Intranet: EHS documents are available at intranet to access EHS MS.
 Printed copy: Updated EHS MS documentation is being provided to site in hard printed copy to access
all the employee/ workmen/ contractor etc.
 EHS Notice/ communication board: Necessary critical EHS information being provided at EHS Notice/
communication board.
 Email/ alert: Necessary information is being provided through email
 EHS meeting: It is conducted as per requirements. Beside this project EHS committee meeting being
organized.
 EHS man power/ execution team: Staff is available to communicate EHS information to relevant
stakeholder.
 Others: Appropriate communication on EHS MS to workmen and their representatives is being
communicated through Tool Box Meeting/ tool box talk, one to one communication, caution board,
other displays, training, awareness meeting, etc.
c) Determine and remove obstacles or barriers to participation and minimize those that cannot be
removed: Obstacles and barriers can include failure to respond to worker inputs or suggestions,
language or literacy barriers, reprisals or threats of reprisals and policies or practices that discourage or
penalize worker participation.
Following measures being taken place:
 Participation in EHS matter e.g. training/ EHS induction/ tool box meeting etc. being done during
working hours.
 Motivating environment by reward and recognition for EHS input.
 Top management/ site management seek input/ consultation from relevant stakeholders.
 Translation assistance being provided to overcome language barrier.
 Provision of EHS suggestion box/ incident reporting box
 Display of emergency contact number of project Head/ EHS coordinator.
 provision of information and communication regarding the scope and objectives of the EHS
management system;
 provision of operational information and training, including knowledge of identified hazards, hazard
elimination and control strategies, and residual risks assessments;
 creating awareness of hazards and EHS risks;
 improving competency;
 provision of adequate time and resources to accomplish the items from bullets a) to c);
 provision of mechanisms to foster, promote and enable effective cooperation between managers and
non-managers e.g. EHS committees as well as provision for the selection of representatives (through
worker or union organizations) in accordance with applicable legal and other requirements;
 providing protection from reprisals, including disciplinary or other adverse measures, for reporting, or
removing themselves from situations of serious danger of imminent harm;
 creating and maintaining a positive culture for the EHS management system for example behaviour
based safety (BBS).
 The provision of personal protective equipment (PPE) at no cost to workers helps to remove an
important barrier to participation in the EHS management system. Hence, contractor/ sub-contractor
shall issue PPEs to workmen at no cost.

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1

5
 Trust among workmen has been created through periodic communication through project
management/ top management while their site visit (safety walk through/ MRC round/ etc.) during
interaction with workmen.
 Behaviour based safety is initiated to change the perception about safety. Bottom up communication
initiatives and involvement of workmen/ their representatives at every steps EHS MS that helps to
build the trust of fearless work environment on timely reporting and response as above mentioned.
d) Emphasize the consultation of non-managerial workers on the following:
 determining the needs and expectations of interested parties;
 establishing the EHS policy;
 assigning organizational roles, responsibilities and authorities, as applicable;
 determining how to fulfil legal requirements and other requirements;
 establishing EHS objectives and planning to achieve them;
 determining applicable controls for outsourcing, procurement and contractors
 determining what needs to be monitored, measured and evaluated;
 planning, establishing, implementing and maintaining an audit programme(s);
 ensuring continual improvement.
This may being done through bottom up communication (as mentioned above) or one to one
discussion/ in formal/ informal meeting. There is also provision to record the evidence of consultation
by signature of non-managerial workers in certain form.
e) Emphasize the participation of non-managerial workers in the following:
 determining the mechanisms for their consultation and participation;
 identifying hazards and assessing risks and opportunities;
 determining actions to eliminate hazards and reduce EHS risks;
 determining competence requirements, training needs, training and evaluating training;
 determining what needs to be communicated and how this will be done;
 determining control measures and their effective implementation and use;
 investigating incidents and nonconformities and determining corrective actions
This may being done through bottom up communication (as mentioned above) or one to one
discussion/ in formal/ informal meeting. There is also provision to record the evidence of consultation
by signature of non-managerial workers in certain form.
Consultation: workmen/ contractor and external interested parties:
Consultation is a two-way communication process. For example, workers nearest to OH&S risks (and, as
applicable, their representatives) can be asked about decisions to be taken to control those OH&S risks
so they can give their opinions about them. Such consultation is being taken from internally from
employees/ workmen/ their representatives/ contractor and supplier etc. and from externally from
external interested parties as and when required.
Consultation with workmen and/ or their representatives and with contractor shall be taken where
there are any changes that affect EHS MS through one to one interaction/ in writing. Representation on
EHS matter shall be encouraged through reward and recognition as required.
Refer management of change procedure as a part of this process manual.
Organisation shall ensure that, when appropriate, relevant external interested parties shall be
consulted about matters pertinent to the EHS management system. CO EHS Team or project team can
hire such interested parties for consultation.
Worker and/ or their representatives shall participate and consult:-
1. Context of the organization: while determining internal and external issues, need and expectation of
workers and other interested parties, scope of EHS MS, EHS MS as per standard ISO 14001:2015 and ISO
45001:2018.
2. Planning: While determining risk and opportunities, hazard identification, risk assessment and
determining control, EIAC, assessment of risks and opportunities, ROR, other risks and opportunities to
the EHS MS, development and review of policies and EHS objective & program & its planning.

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1

6
3. Support: while reviewing and allocating resources, identifying need and assisting in building
necessary competencies, planning/ reviewing the awareness, consideration of diversity aspects (e.g.
language, culture, literacy, disability, others) for information and communication purpose and
appropriate display of documented information to increase reach of EHS information.
4. Operation: while planning and implementing operational control procedures for examples hierarchy
of controls, management of change, procurement, outsourcing, contractor management, emergency
preparedness and response.
5. Performance evaluation: on EHS performance, status of objectives, status of audit/ non conformity,
participation in EHS committee meeting.
6. Improvement: on improvement projects/ initiatives/ efforts to understand view of workmen/ their
representatives. Appropriate involvement in incident investigation.

Doc. Ref: Template COEG10-TTR-GENE-GE-HS-TMT -016 to -019,

Template COEG10-TTR-GENE-GE-HS-TMT-021

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-001, Rev No: R1