TATA Realty

(Tata Housing Development Company Limited)

Project Management Group

SOP for EHS legal requirements and other requirements

(compliance obligation) and evaluation of compliance
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-003, 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-003, Rev No: R1

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 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-003, Rev No: R1

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 SOP for identifying EHS Legal requirements and other
requirements (compliance obligation) and evaluation of
compliance
EHS Legal requirements and other requirements (compliance obligation)
Tata Realty has established, implemented and maintained a process (es) to:
a) determine and have access to up-to-date legal requirements and other requirements that are
applicable to its hazards, OH&S risks and OH&S management system;
b) determine how these legal requirements and other requirements apply to the organization and what
needs to be communicated;
c) take these legal requirements and other requirements into account when establishing,
implementing, maintaining and continually improving its OH&S management system.
Tata Realty has maintained and retained documented information on its legal requirements and other
requirements and shall ensure that it is updated to reflect any changes.

Evaluation of compliance
Tata Realty has established, implemented and maintained this process for evaluating compliance with
legal requirements and other requirements.
Tata Realty:
a) has determine the quarterly frequency for the evaluation of compliance and by method of joint
review by site team for the evaluation of compliance in given template;
b) evaluate compliance by site team and take action if needed in case of incident occur, non-conformity
observed during audit or else;
c) maintain knowledge and understanding of its compliance status with legal requirements and other
requirements may be by organizing training on it or subscribed updates or consultation internal with CO
legal team or externally.

Purpose: The purpose of this process is to facilitate –

 Identification of the applicable statutory, regulatory and other requirements related to
Environmental and Occupational Health & Safety.
 Communicating identified legal/ regulatory & other requirements to all concerned for necessary
action and compliance
 Tracking the amendments in the applicable legal/ other requirements and updating the
information with relevant personnel.
 Monitoring & evaluation of compliance with legal and other requirements.

Scope &Application: This process is applicable to all Projects and Offices of Organisation and its
subsidiaries.

Responsibility & Authority: Responsibilities of identification, communication and updating of applicable

EHS related legal and other requirements are as follow:

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-003, Rev No: R1

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 Sr. Primary Secondary
Process Remark
No. Responsibility Responsibility
1 Identification & preparation of EHS Manager In association with -
Register of Regulation (ROR) Head
2 Communication of legal Corporate EHS Dept. - -
requirements to relevant functions/ Legal function (PWC
projects. These requirements portal)
obtained through subscription or Site EHS Manager
else way.
3 a) Communication of specific Office/ function/ site Project EHS As per
requirements from ROR to Head Manager contract
relevant parties (Contractors, condition
Suppliers) for necessary action
& compliance.
b) Keep a copy of BOCW/ Factory
act/ rule (for Indian Sites)/ Key
EHS act/ rule (for international
projects), IS codes, others as
applicable at minimum basis.
4 Tracking of amendments/ updating Tracking: Nominated Office/ site/
ROR person from project functional Head
head, who liase with
Govt authority, e.g.
Admin.
Update ROR as per
amendment:
EHS Manager/ SPOC
of respective area.
5 Monitoring & evaluation of Office/ site/ EHS Manager/ SPOC
compliance with legal & other functional Head
requirements

Expectations from Compliance Assurance (As per Tata Group Safety and Health Manual):
Ever-changing demands on organisations by society lead to higher standards in safety & health. The
effective result is reflected in a suite of laws, regulations and guidance notes with which organisations
are expected to comply. Legislative requirements are identified and their likely impact assessed, so that
plans to comply are enacted while maintaining a continuous improvement approach. While compliance
to legislative requirement is mandatory, there is an endeavour to exceed applicable regulatory safety &
health requirements, complying with group requirements and aligning to accepted industry standards
and practices.
Expectations:
1. Understanding and identification of applicable safety & health regulatory requirements is done by
sites and this information is kept up-to-date.
2. Information about regulations and industry codes and practices is communicated to
3. appropriate people.
4. A system is in place to identify, assess and interpret regulatory impacts on the site in a
5. way that ensures it remains compliant.
6. The system includes the identification of internal company standards that demand
7. mandatory compliance and industry codes and practices to which the organisation subscribes.

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-003, Rev No: R1

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8. A compliance register is kept and maintained. The register must list the site systems and processes
that deliver compliance.
9. The system ensures that the site identifies and assesses its methods for remaining compliant and
suitable improvement activities form part of the business and strategic plan.
10. A periodic compliance review must be in place and form part of the site risk management strategy.
Process is in place to identify to ensure all amendments and changes to regulatory requirements
(including new requirements) are identified and addressed.
11. Employees with responsibilities for reporting to authorities receive appropriate training and
reporting requirements clearly defined and documented as procedures.
12. Sites undertake periodic compliance assessments against their identified priorities.

Process Flow Chart: Nil

Process Description and Criteria for Identifying Legal and Other Requirements and Implementing
Controls.

Identification of Legal & Other Requirements

 In reference to various legal updates (Sources: EHS magazines, EHS web sites, NSC, Bureau of
Indian Standards, Directorate General, Factory Advice Service and Labour Institute {DGFASALI},
Statutory authorities, EHS professionals, External auditors) and in consultation with the relevant
functions/ dept./ projects, corporate EHS department shall identify EHS legal & other
requirements relevant to the activity, services & products of the organization.
 Corporate EHS department shall develop reference Register of Regulation for Indian Projects in
the TMT-006 containing the detailed information. EHS site Manager will identify state specific
act and rule as applicable and maintain copy of site specific ROR. International Project’s EHS
Manager shall determine EHS legal requirement through consultants/ meeting with statutory
authority/ any other available resources and prepare respective ROR for their site and comply
with it.
 Project Head shall possess a copy of BOCW and Factory of central & state act and rules book, as
applicable. Applicable other act and rule book may also be kept. For international projects, they
shall keep respective copy with them.

Communication of Legal & Other Requirements

 ROR shall be issued to all concerned functions/ project for further communication and
compliance as per document control procedure.
 From ROR, activity/ process/ services specific EHS legal & other requirements shall be
communicated to concerned in-charge by Functional/ Project head.
 The legal and other requirements applicable to contractors/ suppliers shall be communicated
by Functional/ Project Head.

Review & updating of Legal & Other Requirements

 Change in legal & other EHS requirements due to change in activity, products & services or
amendments of the existing legal requirements or new legal requirements shall be identified by
concerned functions/ Project Head and communicated to corporate EHS Function.
 Corporate EHS department shall review the change to adjudge the applicability. Accordingly
ROR shall be updated.
 Corporate EHS department shall also review legal and other requirements annually by referring
subscribed updates, books, websites etc. and update the ROR as per requirements.
 However in case of major amendments/ revision in legal & other requirements, which have a
significant impact on the EHS performance of the organization, the same shall be included in
ROR at the earliest available opportunity.

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-003, Rev No: R1

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  Updated reference ROR shall be communicated to all concerned Function/ Project Head for
necessary action and compliance.
 Function/Project shall identify, prepare, review and maintain Project Specific EHS Legal
requirement and other requirements.

Monitoring & evaluation of Legal & Other Requirements:

 Project Head shall review the compliance to the EHS legal and other requirements at project on
quarterly basis in the month of April, July, Sept and Jan.
 The input from internal audit, accident/ incident investigation report shall also be used by EHS
Head for evaluation of legal compliance.

Documented Information:
Template name Template number
Project Specific Applicability of EHS Legal Requirement COEG10-TTR-GENE-GE-HS-TMT-005
EHS legal and other requirements (compliance obligation) COEG10-TTR-GENE-GE-HS-TMT-006
Key EHS Legal Compliance Details
COEG10-TTR-GENE-GE-HS-TMT-007
(Project Specific Register of Regulation)

TATA Realty
Doc Ref: COEG10-TTR-GENE-GE-HS-SOP-003, Rev No: R1