Environmental and Social
Management System
Implementation Handbook
METAL PRODUCTS MANUFACTURING
2
Although the environmental and social management system described in this
Handbook is based on IFC Performance Standard 1, the process outlined herein
may not provide for meeting all the requirements of IFC Performance Standard 1,
or any other IFC Performance Standard. The purpose of this Handbook is to dem-
onstrate a technical means of integrating environmental and social concerns into
company management, so that a business can become more effective in reducing
its impact on the environment, its workers and its neighboring communities.
The Handbook is provided “AS IS,” and is provided without warranty of any kind,
either express or implied, including, but not limited to, implied warranties of mer-
chantability, tness for a particular purpose, or non-infringement. Development of
an environmental and social management system based on this Handbook does
not imply any type of certication or compliance with any IFC Performance Stan-
dards, including but not limited to IFC Performance Standard 1, nor does it imply
endorsement by or afliation or sponsorship with IFC.
The Handbook is distributed with the understanding that neither the authors, nor
the organizations and countries they represent, nor the publisher, are engaged
in rendering technical advice. The information, policies and procedure templates
comprising the Handbook are intended as a reference and for informational
purposes only, and are not to be relied upon for operational or any other purposes.
Implementation of the Handbook is solely the responsibility and risk of the nal
users. The material in the Handbook is set out in good faith for general guidance,
and no liability can be accepted for any possible loss or expense incurred as a
result of relying on the information contained herein. Neither IFC nor any other
member of the World Bank Group shall be liable for any direct, indirect, incidental,
special, consequential, punitive or exemplary damages, including, but not limited
to, damages for loss of prots, goodwill, use, data or other intangible losses (even
if IFC has been advised of the possibility of such damages) in any way arising or
resulting from use or reliance on the Handbook or any such conclusion or deter-
mination. The Handbook is distributed subject to the condition that it shall not by
way of trade or otherwise be sold or otherwise circulated on a commercial basis
without IFC’s prior written consent.
IFC does not guarantee or provide any warranties as to the accuracy, timeli-
ness, completeness, reliability or usefulness of this publication’s content, and is
not responsible or liable for any such content or use thereof. The views, advice,
opinions and other statements herein are not reviewed or endorsed by, and do not
necessarily represent the views and opinions of IFC or its Board of Directors, the
World Bank or its Executive Directors, or the countries they represent.
3
Table of Contents
Welcome & How to Use is Handbook ....................................................................................4
Section I: Benets of an Environmental and Social Management System in the
Metal Products Manufacturing Industry ......................................................................................7
Section II: Understanding an Environmental and Social Management System .................................. 11
O ..........................................................................................................................12
E E S M S (ESMS) .................................13
S D S I .......................................................15
U T H A C P T D A
I Y ESMS .....................................................................................................16
Section III: Practical Guidelines for Developing and Implementing
Your Environmental and Social Management System ...........................................................17
. P ...........................................................................................................................18
Purpose of an Eective Policy ...........................................................................................18
Modifying Your Existing Policy Statement or Creating a New One .........................................18
Gaining Senior Management and Company Commitment ....................................................19
. I R I .........................................................................20
Key Risks in the Metal Products Manufacturing Industry ....................................................... 20
. M P ..............................................................................................23
Identifying Preventive and Corrective Actions ...................................................................24
Writing an Eective Action Plan .....................................................................................25
Writing an Eective Procedure.........................................................................................26
Short Cases .....................................................................................................................26
. O C C .............................................................38
Roles, Responsibilities and Authorities to Implement the ESMS ..........................................38
Communication and Training .........................................................................................40
. E P R ...................................................................42
Common Hazards and Emergency Situations in the Metal Products Manufacturing Industry .45
Common Emergency Scenarios .........................................................................................49
. S E ..........................................................................................50
Mapping Your Stakeholders .............................................................................................51
Developing a Stakeholder Engagement Plan......................................................................52
. E C G M ...........................................54
External Communication ................................................................................................54
Grievance Mechanism .....................................................................................................54
. O R A C ......................................................57
. M R ............................................................................................58
Indicators .......................................................................................................................59
Measuring and Improving Your ESMS .............................................................................62
Linking Your Action Plan and ESMS Improvement Plan ..................................................63
Conducting an Eective Management Review ..................................................................64
4 Welcome and How to Use this Handbook
Welcome & How to
Use This Handbook
Environmental and social responsibility is becoming
more and more important in today’s global
economy. There are thousands of environmental
and social codes and standards in the world
today. The codes and standards dene the rules
and the objectives. But the challenge is in the
implementation. An environmental and social
management system (ESMS) helps companies to
integrate the rules and objectives into core business
operations, through a set of clearly dened,
repeatable processes.
This Handbook is intended to be a practical guide
to help companies develop and implement an
environmental and social management system,
which should help to improve overall operations.
5
In the current economic climate, companies are
under pressure to perform or even just survive.
New initiatives are often met with resistance as
people struggle to keep up with their day-to-
day responsibilities. Some people think that an
environmental and social management system
must be big, complicated and expensive. But that
is not really true. To be effective, a management
system needs to be scaled to the nature and size of
the company.
If a company has existing management systems for
quality or health and safety, this Handbook will help
to expand them to include environmental and social
performance. Our hope is that this Handbook
will accelerate a company’s journey of continual
improvement, for its own benet and that of its
employees and stakeholders.
6 Welcome and How to Use this Handbook
Quick Reference for Using this Handbook
Sections I – II
These sections provide background on environmental and
social management systems (ESMS).
Section III
This section provides step-by-step instructions on how to
develop and implement an ESMS. If you see a Toolkit icon,
it means that there is an accompanying tool in the ESMS
Toolkit.
ESMS Toolkit
This companion publication gives tools, including forms,
templates, checklists, and other useful documents, to help
you develop and implement the systems described in the
Handbook. We suggest that you adapt each tool for your
company.
ESMS
Self-Assessment
and Improvement
Guide
This companion publication contains a questionnaire,
maturity matrix, and improvement tips to help you
measure the maturity of your ESMS and develop a plan
for improvement.
Acknowledgements
is Handbook was prepared by the Sustainable Business Advisory (SBA)
department with primary contributions from Irene Angeletti, Rob Horner, and
Larissa Luy.
e Handbook is based on primary contributions and technical expertise from
the Social Accountability International (SAI) team of Rachel Kanter Kepnes,
Craig Moss and Jane Hwang with key contributions from D.K.S. Moorthy,
Eileen Kaufman, Dundar Sahin, Richard Rowe, Caroline Lewis, Yogendra
Chaudhry and Priyadarshini Sharma of Tata Steel Limited. Graphic design
services were provided by Pam Henry.
Photography courtesy of IFC ILO Better Work and World Bank Photo Library
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 7
I
Benets of an Environmental
and Social Management System
8 Section I: Benets of an Environmental and Social Management System
Benets of an Environmental
and Social Management
System in the Metal Products
Manufacturing Industry
Today, metal products manufacturing companies are confronted with a num-
ber of signicant environmental and social challenges. None of the challenges
is insurmountable, but if not eectively assessed and managed, they will hurt
your protability, reputation, and prospects for future business.
Among these challenges are increasing energy and raw materials costs, the
growing power and inuence of environmental and labor regulatory agencies
and rapidly evolving consumer awareness and concerns about environmental
and social issues. ese risks are in addition to the primary risk of failing to
deliver high-quality metal products on time and build brand and consumer
condence. All of these risks ultimately have nancial consequences. Moreover,
exports and international exposure are vital to the success of many metal prod-
ucts manufacturing businesses; but exporting your products also increases de-
mands from international legislation, local industry standards, and consumer
requirements. Many of these requirements are increasingly related to environ-
mental and social practices. All of these risks, requirements and pressures on
your business are driving forces that should motivate you to implement a
“Environmental
and social
management
systems are
our framework
for managing
compliance and
achieving continual
improvement
within our
company.”
CSR Ofcer
Multi-national
iron company
“We are facing intense global competition in
the current economic climate. Improving our
environmental and social management helps
us reduce inputs, minimize waste, and improve
our competitiveness and protability.”
Senior VP
Multi-National Producer
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 9
management system. A management system will enable you to consistently
foresee and address issues confronting your business so you can prevent poten-
tial risks from becoming actual problems.
Implementing an environmental and social management system (ESMS) can
have direct business benets. Conserving and using energy and materials more
eciently helps to reduce production costs. Reducing waste and discharges
and increase recycling can minimize costs of waste disposal, which have been
steadily increasing over time. A management system can help you benchmark
your expenditures against industry standards and identify potential production
and operational cost savings.
e same tangible benets can be realized on the social side. Clear, transpar-
ent human resource policies and procedures improve communication between
workers and managers. is helps to anticipate and avoid labor problems.
Eective occupational health and safety management procedures will enable
you to identify workplace and process hazards so you can eliminate or reduce
their potential negative impacts through controls and employee training on
“For our company, socially and environmentally responsible man-
agement is not only an ethical obligation; it is also a tool that
enables us to obtain and maintain competitiveness and pursue
innovation in our eld.”
CEO - Industrial Manufacturer
“Social compliance is a tough dilemma to begin with. Resolving it
takes a systematic approach to each and every issue.“
Managing Director
Multi-national Steel Company
10 Section I: Benets of an Environmental and Social Management System
the avoidance of risks. is can not only reduce near misses, accidents and
fatalities, but can also lead to bottom-line business benets such as reduced
absenteeism and worker turnover, and lower insurance premiums for workers’
compensation.
Many companies already use management systems for quality control and oc-
cupational health and safety. An environmental and social management system
(ESMS) simply extends that approach to the management of your business’s
impact on the environment, your workers and other external stakeholders.
Ultimately, your management systems should be integrated and centralized
in one comprehensive system, instead of having separate systems for quality,
occupational health and safety, and the environment. is handbook will help
you implement an integrated ESMS that is appropriate for the size and nature
of your company.
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 11
II
Understanding an
Environmental and Social
Management System
12 Section II: Understanding an Environmental and Social Management System
Understanding an Environmental and
Social Management System
OVERVIEW
A management system is a set of processes and practices to
consistently implement your company’s policies to meet your business
objectives. The goal is to make sure that you have the appropriate
policies and procedures in place and that people consistently follow
them. The management system helps to assess and control your risks
and is the key to lasting improvement. A key feature is the idea of
continual improvement – an ongoing process of reviewing, correcting
and improving your system. The most common method is the Plan-
Do-Check-Act cycle (PDCA), described below.
DO
PLAN
CHECK
ACT
Identifying and
analyzing the risks
and objectives
What is important for you
as an organization and
what are you going to do
about it?
Developing and
implementing a
potential solution
What actions will you
take? Who, what,
where, when and how?
Measuring how eec-
tive the solution was,
and analyzing whether
it could be improved
Did you see the change you
expected after implementing
the actions?
Implementing the
improved solution
What will you change if
results are not what you
expected?
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 13
In the workplace, an effective management
system is comprised of trained, committed
people routinely following procedures.
ELEMENTS OF AN ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM (ESMS)
A solid, functioning environmental and social management system (ESMS) is made up of interrelated parts.
Take a look at the nine elements of an eective ESMS. Each of these elements is important, because they
help you to assess, control and continually improve your environmental and social performance, as part of
the Plan-Do-Check-Act cycle. e following section presents step-by-step instructions on how to develop
and implement a system using these elements.
14 Section II: Understanding an Environmental and Social Management System
A lot of companies in the metal manufacturing industry already have manage-
ment systems for quality. If so, you may already have elements of an ESMS, and
there is no need to replace what you already have. In this Handbook’s compan-
ion publication, ESMS Self-Assessment and Improvement Guide, we provide a
self-assessment rating for each of the ESMS elements. e self-assessment will
allow you to measure your current level of system development and implementa-
tion. You will answer a series of questions and get your score for each element
in the ESMS on a scale of 0 to 5 (5 is highest). e score measures the maturity
of your system. Once you understand the maturity of your system, it is easier to
target specic steps you can take to improve it.
MEASURING
AND IMPROVING
You can’t improve
what you don’t
measure.
THE SYSTEM MATURITY LEVELS (5 = HIGHEST)
Level 5 Mature system implemented internally and with key supply
chain partners – continual improvement embedded in opera-
tions
Level 4 Systems well developed and implemented internally –
routine improvement projects
Level 3 Systems approach adopted, but development and implemen-
tation is inconsistent – improvement sporadic
Level 2 Limited system development with sporadic implementation –
primarily reactive
Level 1 Little systems awareness or repeatable processes
Level 0 No systems awareness or repeatable processes
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 15
REMEMBER
A carefully developed, detailed ESMS is only
valuable if it is well-implemented.
SYSTEM DEVELOPMENT AND SYSTEM IMPLEMENTATION
One of the most important things to understand about a management system
is the dierence between system development and system implementation. A
management system is comprised of trained, committed people routinely fol-
lowing procedures. If you break this statement down, you see that it talks about
“procedures.” Procedures are the step-by-step way that people follow your poli-
cies. Procedures are the heart of eective system development.
Now let’s look at the other part of the statement – “trained, committed people
routinely following procedures.” is is the implementation. ere is a lot that
goes into making it happen. Of course, some training is important to make sure
that people are aware of the procedures and understand what they are supposed
to do on a routine basis. But you also need to nd a way to get their commit-
ment.
One common observation is that large companies tend to be better at system
development. But they often have diculty getting people in dierent loca-
tions or departments to consistently implement the procedures, despite having
well-documented systems. Small companies tend to be better at system imple-
mentation – if they have eective leadership. However, they are often weak at
developing the documentation needed to ensure continuity when people in the
organization change.
e approach of this Handbook and its companion publications, the Toolkit
and Self-Assessment and Improvement Guide, balances system development and
system implementation in each of the ESMS elements.
DEFINITIONS
System
Development
The documented policies and procedures.
System
Implementation
Trained, committed people routinely follow-
ing the procedures.
An ESMS does not need to be complicated, but it does need to be
documented and then put into practice. Some people mistakenly
think a management system is just documents. But that is only a part
of it. Management systems are about implementation and continual
improvement.
16 Section II: Understanding an Environmental and Social Management System
USING THE HANDBOOK AND COMPANION PUBLICATIONS
TO DEVELOP AND IMPLEMENT YOUR ESMS
e Handbook and companion publications are designed to help you measure
and improve the maturity rating of your ESMS. e owchart below shows
how you can use these three publications in a cycle of continual improvement.
REDO this graphic
ESMS
TOOLKIT
ESMS SELF-
ASSESSMENT &
IMPROVEMENT
GUIDE
ESMS
HANDBOOK
• Understand the benets of an ESMS
• Learn the nine fundamental
elements of an ESMS
• Use tools to implement
improvement plan
• Measure the maturity of your ESMS
• Prioritize elements and develop an
overall ESMS improvement plan
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 17
This section provides step-by-step instructions on
how to develop and implement an ESMS.
For each element of the ESMS, we offer a quick
way to measure where you are now.
When you nd a toolkit icon, it means
there is a tool in the companion publication
Toolkit
to make it easier to get started.
III
Practical Guidelines for
Developing and Implementing
Your Environmental and Social
Management System
18 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
The cornerstone of your ESMS is your set of
policies. Your policies summarize the commitment
that your company has made to managing
environmental and social risks and impacts. They
establish the expectations for conduct in all related
aspects of your business.
5
4
3
2
1
0
PURPOSE OF AN EFFECTIVE POLICY
Simply put, the policies are the rules. ey tell everyone what is allowed and
what is not allowed when it comes to social and environmental issues such as
labor and working conditions, resource eciency and pollution prevention,
and community health, safety and security.
A good practice for writing the policies and making them understood is a Poli-
cy Statement. e Policy Statement communicates your company’s policies to
your management, sta, board, suppliers, contractors, customers and all other
stakeholders. It is important for everyone to have a common understanding
of the core values of the company, how you expect people to behave and how
external stakeholders can expect you to operate.
MODIFYING YOUR EXISTING POLICY STATEMENT OR
CREATING A NEW ONE
e Policy Statement should be clear and simple – it does not need to be long
and technical like a legal document. Many companies already have a corporate
code of conduct that serves as a Policy Statement and includes issues such as
ethics. You can expand your existing code to align with internationally recog-
nized environmental and social standards for issues relevant to your business,
such as the IFC Performance Standards for Environmental and Social Sustain-
ability.
It is important to think through the creation of the Policy Statement and tailor
it to your company operations. In developing your Policy Statement, be aware
of the specic risks you face in the metal products manufacturing industry.
E&S policies and proce-
dures clearly commu-
nicated internally and
externally. Senior man-
agement commitment to
continual improvement.
Full set of E&S policies,
procedures and records,
centrally maintained and
routinely reviewed. Wide
awareness in company.
Policies and procedures
in place meeting selected
E&S standards. Sporadic
communication, imple-
mentation and review.
Policies in place meeting
selected E&S standards.
Sporadic, conicting or
confusing procedures.
Limited E&S policies
in place.
No E&S standards
adopted. No related
policies and procedures.
Policy
ELEMENT 1
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 19
GAINING SENIOR MANAGEMENT AND COMPANY
COMMITMENT
Modifying or adopting your Policy Statement will require senior manage-
ment support. In some companies, it may require approval from the Board of
Directors. A high level of senior management support is critical for integrating
environmental and social commitment throughout all levels of your company.
Committing to environmental and social policies probably requires some
change in the behavior of your company, workers, contractors and suppliers.
is can be challenging. ere are dierent strategies and dierent techniques
for changing organizational behavior, but experts agree that to create lasting
change, senior management must be committed to the eort.
e rst step is building awareness. ere are many issues that occupy your
employees’ attention day-to-day. As just a written document, your Policy
Statement may not get their attention or seem relevant to their daily activities.
Senior management needs to make this Policy Statement come alive.
To do so, they need to communicate the importance of environmental and
social issues, by making them an ongoing part of high-level Board and man-
agement discussions, public speeches, and messages to employees.
Once people are aware of the Policy Statement, the next step is building com-
mitment – also known as “buy-in.” You will probably meet resistance: “Why
do we need to do this? It is too much work. I’ve already got enough to do.
How does this help our bottom-line?” Senior management needs to eectively
shape and communicate the message internally and externally. ey need to
send a clear message that this is a long-term commitment by the company.
e key message is that this
will contribute to the com-
pany’s success and that each
person will benet - but that
they will also be held ac-
countable.
Once you have convinced people that they need to do something, senior
management needs to drive implementation. ey do not need to lead the
eort on a day-to-day operational level, but they do need to adopt the policy
and oversee the implementation plan. Resources will be necessary in order to
communicate the policy internally and externally, integrate new procedures
and train all relevant sta and suppliers.
Crafting the initial messages can be a good time to talk through the above
stages with your senior man-
agement. Consider accompa-
nying the Policy Statements
with a message from the CEO.
Use the Toolkit item Checklist for
Developing a Company Policy
Statement to get ideas of what you
could include in your policy.
For any change
initiative, think
of three critical
stages:
Awareness;
Commitment;
and
Implementation.
Your senior
management
can help you to
accelerate all
three stages.
Use the Toolkit item CEO Letter
Announcing the ESMS - Internal to
get started.
1. Policy
20 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
The primary objective of a risk assessment is to
identify the potential negative environmental
and social impacts so that you can develop the
appropriate strategies to address them.
In the following pages, we present the key issues
that come up in the metal products manufacturing
industry.
Mature system, routinely
reviewed and updated
as part of a continual
improvement plan. Internal
and external inputs. Proce-
dures extended to contrac-
tors, subcontractors, third
parties and supply chain
as relevant.
Systematic, documented
identication and prior-
itization of E&S risks
and impacts. Routinely
reviewed and updated
across existing, new and
changing activities. Wide
awareness and engage-
ment in company.
Awareness and engage-
ment of staff in identica-
tion and prioritization of
E&S risks and impacts.
External experts involved
as required.
Procedures in place for
identication of E&S risks
and impacts across all key
activities.
Basic identication and
assessment of E&S risks
and impacts, but limited
to a few activities.
No identication or
assessment of E&S
risks and impacts.
5
4
3
2
1
0
ELEMENT 2
Identication of Risks
and Impacts
KEY RISKS AND IMPACTS IN THE METAL PRODUCTS
MANUFACTURING INDUSTRY
1. Environmental: Pollution Prevention and Resource Efciency
• Release of hazardous air pollutants such as hexavalent chromium, manganese,
nickel, and other metals and metal oxides from welding and thermal cutting
processes
• Release of volatile organic compounds (VOCs) and solvent vapors containing
ammonia and ammonium chloride from metal degreasing, cleaning, and
painting processes
• Generation of liquid waste from wet scrubbing used for air emissions control,
spent metal working uids, spent quenching baths, spent degreasing and
cleaning solvents, and spent surface nishing baths
• Generation of large amounts of sludge from wastewater treatment, and metal
surface cleaning and nishing processes (e.g. coating, galvanizing, electroplating)
• Generation of solid waste from welding and thermal cutting
• Non-recycling of metal dust or scrap from metal forming, cutting, or grinding
processes; and, dust collected from air pollution control devices
• Improper disposal of empty paint containers
• High water consumption in water-cooling and washing processes
• High energy consumption, especially fuel oil, engine oil and petrol, for metal
forming and cutting equipment, as well as by forklifts or cranes used to transport
materials within the factory
• Improper disposal of batteries used for diesel generators
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 21
2. Occupational Health and Safety
• Injuries such as crushed limbs and digits from hydraulic forming presses, metal
working punches, drill presses, and other metal forming tools and machines
• Cuts, abrasions, and puncture wounds from metal cutting tools and machines
• Eye and soft tissue injuries from ying metallic particles
• Exposure to metallic fumes, metal dust, phosgene gas, and VOCs resulting in
metal fume fever and other respiratory and Central Nervous System (CNS)
illnesses
• Respiratory and dermal exposure to toxic and carcinogenic metals, metal
working uids, chlorinated and non-chlorinated metal cleaning solvents,
priming and painting compounds
• Exposure to extreme temperatures and unsafe levels of noise
• Exposure to radiation from welding and non-invasive testing (e.g. x-ray stations
for continuous monitoring of product quality)
• Accidental collision with moving items, cranes and forklifts
• Injuries due to falling objects from heights, or workers falling from heights
3. Labor
• Stigmatization and fragmentation of labor unions
• Lack of social security or government entitlements for contract workers
• Exclusion of contract workers from worker unions
• Failure to provide accident/injury compensation per law for contract workers
• Lack of adequate training on use of PPE, especially amongst contract workers
• Lack of proper facilities, such as canteen, clean drinking water, hygienic storage
of food, which can aect hygiene and health of workers
• Excessive overtime not properly compensated or unrealistic production quotas
• Failure to compensate at minimum wage or insucient wages to achieve a
reasonable standard of living
• Use of child labor
4. Community Health, Safety and Security
• Ground or surface water contamination due to improper management of
wastewater and liquid wastes
• Exposure to hazardous materials and hazardous waste due to improper transport
and disposal
• Exposure to air emissions from various metal production processes
• Use of private security personnel leading to risk of violence against community
members
• Increased vehicle trac due to the transport of raw materials and nished
products to/from the factories
• Dangers from industrial res or accidents, including the release of harmful
substances and chemical spills
2. Identication of Risks and Impacts
Top 3 risks and
opportunities in
the Metal Products
Manufacturing
Industry
1
There is a high risk of
accidents and severe
injuries in the industry. The
types of processes, chemi-
cals, and machines used in
metal production create an
environment where per-
sonal protective equipment
and proper safety practices
are essential. The lack of
investment in personal pro-
tective equipment – both
nancially and in terms of
training time for workers
– can have serious implica-
tions for workers’ health
and safety.
2
Fire and explosion
hazards from combus-
tible metal dust, combined
with ineffective emergency
planning, can have disas-
trous impacts on workers
and businesses in the
industry. Safety planning
and frequent training are
required to prevent res
from occurring and prepare
workers to respond to any
emergency that may arise.
22 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
Now that you have an understanding of the typical risks in
the metal products manufacturing industry, you can rst
use the Risk Identication Worksheet to identify your
potential risks and negative impacts based on your operations
and operating environment. en you can use the Process
Mapping or the Physical Mapping tools to identify in
more detail where problems are likely to arise within your
production process.
Often it is not possible or practical for you to deal with every
single environmental and social impact that your company
could possibly have. You can use the Risk Assessment Form
to prioritize which risks should be addressed rst.
For more information on environmental, OHS and community risks
and impacts in your industry, consult the WBG EHS Guidelines at
www.ifc.org/sustainability.
The following are key considerations for a robust risk
assessment system:
• Cover environmental, OHS, labor and community risks;
• Conduct at regular intervals – at least once a year;
• Conduct any time there are signicant changes to
operations;
• Conduct any time there are external changes such as
new laws or regulations;
• Include input from all levels of workers and managers;
• Include input from affected communities and other
external stakeholders;
• Use external consultants and experts if your staff does
not have the capability;
• Assess and prioritize risks according to both the severity
and probability of negative impacts;
• Consider risks in your supply chain in addition to those
in your company; and
• Scale as appropriate to the size and complexity of your
business.
3
Solid and liquid waste
from metal cleaning
and finishing processes
may contain toxic and
carcinogenic substances
that can contaminate areas
surrounding facilities.
Air emissions containing
metals and volatile organic
compounds (VOCs) can
also contribute to environ-
mental pollution. The use
of pollution prevention
methods and proper waste
treatment and disposal can
reduce negative impacts
to the environment and
decrease health risks from
contaminated air, soil and
water.
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 23
Management Programs are centered on Action
Plans and improved procedures to avoid, minimize
or compensate for the risks and impacts that were
identied.
For example, if you have a policy commitment
to avoid discrimination in the workplace and you
have identied this as a risk factor based on the
lack of a system for employees to express their
complaints, you may implement a complaint
procedure as a way to minimize the risk of
discrimination. Or, if one of your policy objectives
is the reduction of hazardous waste and you
have identied this as a risk factor because of the
high percentage of chemical waste produced in
your plant, you may take action by using fewer
hazardous chemicals.
5
4
3
2
1
0
Veried progress against
objectives and targets;
signicant improvements
in E&S performance. Dem-
onstrated commitment to
continual improvement
using annual improvement
plans.
Routine, consistent imple-
mentation of actions/
activities to proactively
manage E&S risks and
impacts. Measurable com-
pany-wide objectives and
targets. Periodic review
and update.
Actions/activities in place
to manage E&S risks and
impacts, following the
mitigation hierarchy –
avoid, minimize, offset/
compensate. Proactive
approach to managing
issues.
Procedures and assigned
responsibilities to address
and mitigate E&S risks
and impacts across all key
activities. Primarily reac-
tive.
A few informal programs
or activities to mitigate
E&S impacts. No systems
awareness or repeatable
processes
No process for mitigating
E&S risks and impacts.
ELEMENT 3
Management
Programs
24 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
IDENTIFYING PREVENTIVE AND CORRECTIVE ACTIONS
It is good practice to emphasize preventive and proactive actions: (1) try to
avoid causing social or environmental damage; (2) if not possible, then mini-
mize the impact; (3) if not possible, then compensate or oset the damage.
First, attempt to take actions to avoid or prevent the negative impacts. For
example, suppose you are expanding operations and have identied potable
water as a key risk. You might change your new facility location or design it
dierently, so that you avoid contamination of groundwater close to home-
owners and communities. Or, suppose you have identied a certain process
that exposes workers to toxic chemicals and pollutes the local river
system. You might change your manufacturing processes processes
to avoid using these chemicals.
In many cases, complete avoidance is not possible – you may not
be able to relocate or nd alternative processes or materials. In these
cases, you should try to minimize the impact. For example, suppose
that you are located in an area where women are traditionally given
lower status and less access to education, and in the workplace they
are often mistreated by male co-workers and supervisors. Given
this cultural context, it is important to be clear in your recruitment,
hiring and training procedures, in order to make sure that women
are hired on equitable terms and given equal access to training and promotion
opportunities. You can also develop non-discrimination procedures to ensure
that rules for recruitment, hiring and training are clear for everyone to follow.
Additionally, you can conduct training to make sure that everyone is aware of
and follows the procedures.
In some cases, it may not be possible to completely avoid or minimize certain
negative impacts. en you should nd ways to oset them with comparable
positive impacts or provide compensation to those impacted. For example,
suppose your operation uses a large amount of water. Despite taking action to
minimize water consumption, there are still periods of the year when water be-
comes scarce in the local community. You might collaborate with community
leaders to dig new wells or provide alternate sources of drinking water.
Prioritizing Your Actions
AVOID
MINIMIZE
COMPENSATE/OFFSET
3. Management Programs
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 25
WRITING AN EFFECTIVE ACTION PLAN
Whatever actions you decide to take, think of them as a continual improvement
process - you will need to set targets, set deadlines, measure the results, and ad-
just the plans if necessary. You need to assign responsibilities and start to involve
the right internal people and departments.
As you develop your Action Plans, these are the key questions that you need to
think about:
• What – environmental and social risks you want to address
• How – related actions and procedures to be implemented to address the risk
• Why – reasons (objectives) for the actions and procedures, and the expected
results (targets)
• When – timeframe and deadlines
• Who – responsible people
e above examples address some of the risks highlighted in the metal products
manufacturing industry. ese are just some of the actions that might be taken.
You can adapt them to your situation and add as needed – be exible to meet
your company’s specic situation. As you tailor your action plans, consult with
your workers and managers, experts and external stakeholders, including your
suppliers and community. ey can oer insight into important issues and eec-
tive actions. ey can also help you obtain commitment for plans you are trying
to implement, and provide candid feedback about how well the plans are work-
ing. is will be critical to the continual improvement of your systems.
Use the Toolkit item Action Plan Chart to get started.
For recommendations on how to address environmental, OHS and
community risks and impacts in your industry, consult the
WBG EHS
Guidelines
at www.ifc.org/sustainability.
3. Management Programs
26 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
WRITING AN EFFECTIVE PROCEDURE
Procedures serve as step-by-step instructions for workers, supervisors and
managers. ey allow for everyone to have a common understanding of how
to behave. ey enable the rules to be followed even when there is sta turn-
over. Clear, detailed procedures help to embed your social and environmental
policies into your daily operations.
It is a good practice to document your procedures. e key is to make your
procedures as clear and as brief as possible. You can use text, checklists,
owcharts, or simple illustrations. e format for your procedure can vary
depending on the audience. A written procedure may be more appropriate for
managers and supervisors, while illustrations may be useful when dealing with
less literate or immigrant workers. Keep your procedure as short and simple as
possible.
Simply documenting a procedure is not enough. Eective implementation is
the ultimate goal. Most importantly, employees need to be aware that a new
procedure exists and understand why it is important to follow. ey need the
skills and knowledge to be able to implement it. is is achieved through
routine communication and eective training. You will learn more about this
in the next chapter, Organizational Capacity and Competency.
Finally, you must ensure that your employees have access to the current version
of each procedure. Out-of-date documentation should be removed or clearly
marked as outdated to ensure that no one unintentionally follows the old
procedure.
Use the Toolkit item Outline of Procedure and the
Sample Procedure Flowchart to get started.
3. Management Programs
SHORT CASES
Here we present several short cases that illustrate some of the
actions that companies can take to avoid, minimize or offset/
compensate common environmental and social key risks in the
metal products manufacturing industry. Action Plans can be scaled
to the size of your company and the nature of the risks you face.
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 27
Electroplating Plant
RISK: Improper disposal and treatment of
wastewater and hazardous waste
IMPACT
• Contamination of soil and water sources
AVOID
• Assign pollution prevention responsibilities and authority to properly trained individual(s)
to analyze, evaluate and implement pollution prevention methods, such as:
• Replace hexavalent chromium, cadmium, and cyanide-based plating processes
• Recycle and extend the life of process baths (spent baths should be sent for recovery of
plating chemicals and not discharged into wastewater treatment units)
• Reduce the use of rinse waters (e.g. reduce drag-out)
• Minimize and recycle metal sludge from spent baths and wastewater treatment plants
MINIMIZE
• Develop and implement policies and procedures for the proper segregation, treatment
and disposal of hazardous wastes generated from the electroplating processes
• Regularly train workers on the proper labeling, handling and storage of chemicals and
hazardous wastes
• Explore the possibility of sharing a common wastewater treatment plant with other small
electroplating facilities. Wastewater must be pretreated to ensure cyanide destruction and
conversion of hexavalent chromium into trivalent chromium
OFFSET
• Assist in the remediation of contaminated community sites and water supplies
CASE STUDY: PERU
Quality Electroplating is a small independent electroplating company based in Lima, Peru. A
recent article published by a local environmental NGO has raised concerns about the pollution
from the small informal electroplating industry in the country, and specically identied Quality
Electroplating for its poor practices. Because the company is small and located in a mostly com-
mercial area, it has been struggling to afford the costs of wastewater treatment. The company
has been part of the steady growth of poorly monitored independent, small- to medium-scale
electroplating units. The article claims that they are contributing to soil and groundwater pollu-
tion in the city and highlights rising concerns about processes that use highly toxic or carcinogenic
materials that are difcult to destroy, stabilize and dispose of in an environmentally sound way.
Some of these processes include hexavalent chromium, cadmium, and cyanide-based plating. The
company has received increasing numbers of complaints from local community members and has
decided to review its practices to address the issue.
3. Management Programs
28 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
IMPACT
• Emission of greenhouse gases
• Increased air emissions
AVOID
• Measure energy use per process and machine to benchmark use against industry standards
and identify inefciencies.
• Replace old and outdated machines with energy efcient technology.
• Identify and implement opportunities for heat recovery (e.g. exhaust heat from curing
ovens).
• Install a voltage optimization system to prevent overvoltage or undervoltage.
• Invest in renewable energy sources.
MINIMIZE
• Implement an energy conservation awareness and training program for workers, supervi-
sors and area managers. Train workers to switch off machines and lights when not in use.
• Insulate ovens to prevent heat waste.
• Examine wiring and replace or repair damaged wires so they do not leak electricity.
• Retrot facility lighting and install energy efcient lighting, timer switches, daylight
sensors and motion-activated lighting.
• Implement a program for regular maintenance, in order to improve the energy efciency
of equipment.
• Review and revise production schedules so that high energy consuming equipment is used
efciently (e.g. batch operation to reduce machine operation time). Schedule “rolling
blackouts” with the local power generation authority to plan for blackout times.
Metal Fabrication
RISK: High Energy Consumption
CASE STUDY: PAKISTAN
SBD Metal Fabrication is a small sheet metal manufacturer in Pakistan that produces chemical
handling fume cabinets and hoods. The factory operates as many hours as possible each day in
order to maximize the use of its machinery, such as sandblasters and ovens for powder coated
metal. Production has often been halted due to electricity blackouts, so the company usually
leaves the machines on overnight so that they can be used whenever electricity becomes avail-
able. The company recently purchased a generator to ensure that it can continue its production
during the blackouts, but the cost of fuel is more than expected due to the increasing number of
blackouts. The percentage of total production costs spent on energy increased 30%. This is unsus-
tainable for the company, so the owner has instructed the managers to look into alternatives to
cut energy costs and decrease consumption.
3. Management Programs
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 29
Metal Stamping Company
RISK: Use of cleaning solvents containing
hazardous chemicals
IMPACT
• Worker illnesses due to respiratory exposure to hazardous cleaning solvents
• Negative health impacts on community members due to ingestion of drinking water
contaminated with hazardous cleaning solvents
AVOID
• Replace solvent-based cleaning units with alternative processes, such as mechanical clean-
ing, ultrasonic degreasing technology, or biological cleaning in aqueous solutions.
• Substitute TCE with less hazardous cleaning and degreasing solutions.
• Modify working methods to reduce the need for cleaning.
MINIMIZE
• Train personnel on procedures for the safe handling of degreasers, including setting safety
devices, maintaining the correct solvent level and monitoring its degree of decomposition,
unloading and loading machines at correct speed, repairing leaks, and cleaning effectively.
• Reduce vapor emissions by installing degreasers with improved enclosure and vapor con-
densation systems, and avoiding air turbulence close to the work area.
• Control vapor emissions through the installation of rim ventilation (lip extraction) on the
sides of the degreaser; pass vapor through an adsorption media (e.g. activated carbon)
before releasing it to the atmosphere.
• Install an on-site solvent recycling and recovery system or contract the services of a solvent
recovery rm to do so.
• Ship solvent waste to an accredited Treatment Storage and Disposal Facility (TSDF) for
recovery, or dispose of it through controlled incineration.
OFFSET
• Assist in the remediation of water sources contaminated by TCE
• Provide compensation and proper healthcare to workers and community members
impacted by TCE exposure, according to local and national regulations
CASE STUDY: USA
A metal stamping company in Indiana, USA is being investigated by local authorities for improper
disposal of trichloroethylene (TCE) from its degreasing operations by local authorities. TCE is a
halogenated volatile organic compound (VOC) widely used for cleaning processes in the industry
since it evaporates quickly, is cost effective and can be used for many different types of metals.
However, the Indiana Department of Environmental Management recently passed a mandate that
companies must reduce their use of TCE due to its negative health impacts. TCE exposure through
inhalation or ingestion of contaminated drinking water has been associated with central nervous
system (CNS) symptoms such as dizziness, headaches and confusion, and can increase the risk of
liver and kidney cancer. A recent inspection of the company detected the odor of TCE and found
four degreasing machines using it. The company claimed that the machines were old and sched-
uled to be replaced over the next few months. Further inspection determined that the company
was improperly disposing the spent TCE, leading to the probable contamination of local drinking
water supplies. The company is now under further investigation for improper business practices.
3. Management Programs
30 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
Metal Cutting Company
RISK: Worker exposure to metalworking uids
CASE STUDY: BULGARIA
Best Metalworks is a medium-sized metal cutting company in Bulgaria that produces a variety
of different metal parts for medical devices. The company has seen increasing rates of employee
turnover and employee absenteeism due to health issues. Many workers are complaining of skin
irritation, difculty breathing and other respiratory conditions, such as asthma and bronchitis. A
group of workers recently quit after only six months on the job because of health problems and
a worker who has been with the company for decades was recently diagnosed with cancer. These
issues have been traced to exposure to metalworking uids (MWFs). MWFs are used to decrease
heat and friction in metal production operations and remove small metal particles from grinding
and other processes. Workers can be exposed to MWFs by inhaling the vapor or mist or through
skin contact (e.g. from splashed liquid). The company asserts that all workers are instructed to
wear personal protective equipment (PPE) to limit their exposure. However, workers have to pay
for their own PPE. As a result, many workers do not actually use the PPE and are vulnerable to
MWF exposure. Many workers also do not remember any training on proper handling of MWFs.
IMPACT
• Negative health impacts on workers
AVOID
• Obtain Material Safety Data Sheets (MSDS) from suppliers to learn about MWFs’ composi-
tion and associated hazards. Select and use MWFs with the lowest amount of toxic materials.
• Install ventilation systems and maintain them regularly to ensure that they are working
properly. Repair and replace the systems as needed.
• Develop and implement policies and procedures for the proper handling of MWFs and
maintenance of equipment to reduce MWFs contamination.
• Place washing stations close to the work area to encourage good washing practices.
MINIMIZE
• Develop and implement a training program for all metalworking personnel about the
hazards of MWFs and techniques to avoid and limit exposure, including regular housekeep-
ing, proper cleaning techniques and appropriate use of personal protective equipment.
Include information on good hygiene practices to limit exposure, such as regular hand-
washing and changing contaminated clothing.
• Based on a risk assessment, provide personnel with appropriate protective equipment free
of charge (e.g. “resistant to oil” or oil-proof respiratory protection, goggles, face shields,
gloves, chemical-resistant clothing).
• Install emergency showers near working areas.
• Regularly assess workers’ exposure to MWFs. Identify high exposure tasks and monitor
them through the appropriate air sampling strategy (e.g. personal air sampling). Monitoring
results will determine if engineering and work practice controls are effective.
• Periodically conduct medical screenings of workers exposed to MWFs to facilitate early
diagnosis and treatment of associated diseases. Examination should include an employee-
completed health questionnaire, limited examination of the areas of the body at risk (lungs
and skin), and measurement of lung function (pulmonary capacity test).
• Maintain records of all MWF-related accidents and worker’s medical screenings. Conduct
regular review and root-cause analysis.
OFFSET
• Provide medical care and timely assistance to affected workers.
• Compensate for work-related health impacts and loss of ability to work according to local
and national regulations.
3. Management Programs
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 31
IMPACT
• Worker illnesses and loss of life
AVOID
• Modify processes and implement new methods, such as cold jointing techniques, to decrease
the need for hot work overall.
• Install forced exhaust ventilation systems in working areas and implement a regular mainte-
nance program to ensure that they are consistently effective. Install spark arresters in welding
fume extraction systems to prevent res.
• Train workers about the hazards of metal fumes and safe work practices.
• Develop, implement and communicate emergency preparedness and response procedures in
case of re from ignited fumes. Regularly train workers on re response and conduct evacua-
tion drills in all shifts.
• Eliminate the use of specic plating materials (e.g. cadmium) that produce the worst health
impacts.
MINIMIZE
• Assess current welding techniques and replace them with methods that produce fewer fumes.
• Ensure that metals are cleaned properly prior to welding. Remove coatings that increase the
toxicity of fumes.
• Assess work stations and reposition workers so that they are not positioned directly in the
fume cloud. Develop and implement policies and procedures regarding working hours,
breaks and paid sick days. Limit workers’ overtime and ensure they take regular breaks to
reduce exposure time.
• Monitor workers’ exposure to welding fumes regularly through the appropriate air sam-
pling strategy (e.g. personal air sampling) to check if controls in place are effective.
• Based on a risk assessment provide personnel with appropriate PPE free of charge. Train
workers on the proper use and maintenance of their PPE, and monitor regularly to ensure
workers are using their PPE correctly.
• Establish and follow a maintenance schedule for welding machinery. Train workers on
proper maintenance procedures. Conduct periodic medical check-ups for workers to
monitor health impacts of metal fumes.
• Train workers to identify symptoms of welding fumes exposure and encourage them to
report issues to their supervisors.
OFFSET
• Provide compensation and proper healthcare to workers impacted by metal fume exposure
according to local and national regulations.
Pipe Construction Company
RISK: Worker exposure to welding fumes
CASE STUDY: BANGLADESH
Metal Pipes is a medium-sized pipe production company in Bangladesh. The company is pro-
ducing pipes for a buried pipeline project that will improve irrigation in certain areas of the
country. The client recently halted production due to the deaths of two workers and concerns
about working conditions. The company claimed to have no connection to the deaths. However,
many workers complain of u-like symptoms, especially at the beginning of the work week.
Since they are not paid for sick days, none of the workers have taken any time off from work.
Further investigation into the source of the illness and cause of death determined that the
workers are regularly exposed to high levels of welding fumes. The workers who died had acute
exposure to welding fumes because they worked in a conned, unventilated space. Welding
fumes are formed during the heating of metal in welding processes. Exposure can produce sig-
nicant health impacts, including metal fume fever, asthma, cancer and even death. The fumes
can also ignite if they interact with ames. The company claimed to have instituted control
measures, but the workers were not using any personal protective equipment (PPE), and there
are no ventilation systems in the facility. As a result, workers are exposed to welding fumes for
eight to ten hours each day in non-ventilated spaces.
3. Management Programs
32 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
Construction Material Manufacturer
RISK: Malfunctioning or improperly used machines
IMPACT
• Worker injury due to traumatic amputations and loss of digits
AVOID
• Develop and implement policies and procedures for the proper maintenance of all
machines in accordance with manufacturer’s specications to ensure they are in safe
working condition.
• Shut down and repair machines the rst time that they malfunction to prevent possible
incidents. Do not allow workers to use malfunctioning machinery.
• Replace machines when they have become ineffective or pose a danger to workers. Install
effective safeguards on machinery to prevent hands, arms, and other body parts from
contacting hazardous moving parts.
• Arrange work areas so that workers can easily access equipment and controls without
reaching across moving parts.
• Inspect machines regularly and update risk assessments accordingly. Include an assessment
of all potentially hazardous interactions that workers might have with machines.
MINIMIZE
• Implement an orientation and on-going training program for all workers to inform and
remind them about workplace hazards and how to safely operate machinery. As part
of the training, instruct workers not to wear loose-tting clothing, dangling jewelry or
expose long hair, since these can become caught in machines. Workers should also lock out
equipment before clearing obstructions or doing any maintenance.
• Assign a responsible staff member to monitor workers who interact with the moving parts
of machinery.
• Post work instructions for safely operating equipment throughout the facility in a form
that workers can understand (e.g. in their native language or using illustrations).
• Instruct workers to report any unsafe conditions.
• Provide proper lighting in each work area.
OFFSET
• Provide medical care for workers who are injured in the workplace.
• Provide compensation for worker injury or lost ability to work, according to local and
national regulations.
MTC is a large steel manufacturer in Turkey. The company is one of the oldest in the country and
produces steel channels, anchors and other products for construction. The company has had plans
to update its facility and machines for years, but has not yet implemented them. As a result, many
of the machines are 5 to 10 years old. Recently, a worker was injured while operating a 10-year
old computer numerical control (CNC) punch press that did not have proper safeguards in place.
The multi-punch press had a malfunctioning part, which caused it to punch two holes simultane-
ously instead of one. The worker was new to the company and had not been trained properly,
so he reached across the front of the machine to push the malfunctioning part back into place.
When the punch press cycled, the worker’s hand became caught in a pinch point between the top
of the ram and the machine housing, and three of his ngers were crushed by the machine. The
company claimed that the accident was caused by worker carelessness.
CASE STUDY: TURKEY
3. Management Programs
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 33
Automotive Parts Manufacturer
RISK: High concentration of metal dust in the workplace
IMPACT
• Worker illnesses due to airborne contaminants in the workplace
• Fatal and nonfatal worker injuries due to explosions
AVOID
• Annually conduct a re and emergency risk assessment to evaluate root causes of potential
explosions, focusing especially on combustible and water-reactive metal dust.
• Install a dust collection system to efciently capture dust from equipment. Hoods, enclosures,
ductwork and collectors must be appropriately designed and built to reduce risks of explosion
(see National Fire Protection Association - NFPA standards).
• Regularly monitor the concentration of metal nes in the ductwork to ensure that it is safely
below the lower explosive limit.
• Regularly monitor the concentration of airborne metal nes in the workplace to ensure that it
is below the occupational exposure limits.
• Implement a dust housekeeping program to regularly clean and remove dust from the factory.
• Ensure that Safety Data Sheets (SDSs) are completed and available for all materials.
MINIMIZE
• Install appropriate re and explosion protection systems (e.g. isolation, suppression and
venting devices).
• Ensure that proper and adequate re suppressing agents are in place throughout the facility,
such as a Class D type re extinguisher. Do not use water or foam re extinguishers on com-
bustible metal res due to the water-reactivity of alkali metals.
• Establish, communicate and implement a re safety and emergency preparedness and
response plan through a joint worker-manager occupational health and safety committee.
• Conduct worker trainings on emergency preparedness and response procedures, including
identication of workplace hazards, safe operation of machines, use of re and explosion
protection systems, equipment maintenance, and housekeeping procedures.
• Assemble and regularly train re-ghting and emergency response teams. The number of
responders must be proportional to the total workforce and there should be at least one for
each section of the facility.
• Conduct emergency drills regularly for workers in all shifts, including contract and temporary
workers.
• Implement a risk-free communication channel to receive workers’ feedback on health and
safety conditions in the workplace, especially related to the build-up of combustible dust.
Reward workers for alerting management to hazards.
OFFSET
• Provide medical care to those injured in the workplace.
• Compensate for loss of life and loss of ability to work due to injury according to local/national
laws and regulations.
• Ensure that workers continue to receive salary until re-opening of area damaged by explosion.
CASE STUDY: CHINA
RIMS Co. is a metal products company in eastern China. The company employs 450 workers and
specializes in polishing metal wheel rims for automobile companies. This process produces a signi-
cant amount of metal dust, especially aluminum and magnesium. Many workers have complained
that it is difcult to breathe in the factory since the dust goes through their face masks. They leave
the factory covered in grey dust. A couple of weeks ago, there was an explosion at a similar factory
nearby. Investigators have determined that the explosion was caused by the ignition of built-up com-
bustible metal dust in the ventilation ducts. The explosion killed 50 people and injured 150 workers.
This horrible accident brought attention to metal products companies in the area. The management
of RIMS Co. is now determined to prevent a similar accident from happening in its factory and is
taking steps to improve its dust removal processes.
3. Management Programs
34 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
Steel Manufacturer
RISK: Lack of protection for temporary/contract workers
IMPACT
• Worker injury or loss of life due to lack of safety training
• Worker economic insecurity due to lack of legal protection or social insurance
AVOID
• Develop and implement policies and procedures regarding workers’ compensation insurance.
Communicate policies to labor contractor. Do not assign workers to hazardous jobs unless
proof of insurance coverage is provided.
MINIMIZE
• Provide workers with appropriate PPE free of charge based on a risk assessment. Safety
belt and harness should be made of materials strong enough to hold the weight of the
worker in case of an accidental fall.
• Train workers, including contract workers, on safety procedures and use of PPE. Ensure
that workers understand the instructions by conducting a simulation prior to worker de-
ployment at the worksite.
• Assign a responsible staff member to monitor working platforms and ensure that they are
properly installed. Structures should be equipped with safety nets, be fastened and bolted
properly, and have appropriate fasteners where workers can clamp their harness hook.
• Assign a responsible staff member to monitor working practices of workers in hazardous
jobs.
• Record all accidents and near misses, including those involving contractors, and conduct an
analysis to identify the root causes.
OFFSET
• Provide medical care for workers who are injured in the workplace.
• Work with the contractor to provide compensation for worker injury and lost ability to work
according to local and national regulations.
CASE STUDY: INDIA
ABC Manufacturing is a large steel manufacturing company in India. The company employs con-
tract workers to carry out temporary projects at its manufacturing facility. In total, the company
hires approximately 1,500 contract workers on a regular basis from a variety of different labor
contractors. One recent project required workers to work on raised platforms. This work can
be dangerous and requires appropriate use of personal protective equipment (PPE). However,
many of the workers are not trained properly and do not wear the proper harness or neglect to
fasten the hook to a rm supporting structure above the working platform. This can cause ac-
cidental falls. Recently, one worker fell and broke his leg during his rst month on the job. As a
contract worker, he should have received a state insurance card, which covers any hospitalization
or medical treatment. However, he never received his insurance card and had to pay for all of his
medical costs due to the accident out of pocket. The company refused to compensate him for the
costs since he was hired through a labor contractor. The contractor also refused to accept respon-
sibility. He could not afford the costs and had to borrow money at a high interest rate from a local
money lender.
3. Management Programs
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 35
Boiler Manufacturer
RISK: Excessive overtime
IMPACT
• Workplace injuries/illnesses caused by workers’ fatigue due to excessive overtime
• Reduced product quality and lost business
• Suspension of operating license and damage to company’s reputation
AVOID
• Review current production planning to avoid committing to unrealistic delivery schedules.
Restrict contracts to orders that are feasible to complete within the legal working hours.
• Develop, communicate and implement policies and procedures for working hours in confor-
mance with national laws, including provisions for overtime work:
• Normal working hours should not exceed 48 hours per week and workers should receive
at least one day off after every six consecutive working days, unless there are exceptions
in national law or collective bargaining agreements.
• Overtime should not exceed 12 hours per week
• Overtime should not be mandated on a regular basis and workers should be allowed to
refuse overtime without penalty.
MINIMIZE
• Identify processes that can be modied to shorten the amount of time needed for produc-
tion and delivery.
• Develop and implement strategies to recruit skilled workers. Consider providing incentives,
such as transportation to/from the facility and the nearest city, accommodation for workers
(according to decent standards) and an educational facility for workers’ children.
• Establish connections with technical training institutes to recruit trainees with the necessary
skill level. Ensure that the trainee program is conducted according to regulations and does
not expose young workers to hazardous situations.
• Add shifts, modify the timing of shifts, or create more exible working schedules to mini-
mize overtime in any single shift operation. Develop a long-term vendor development plan
to meet exigencies of workload through sub-contracting to reliable suppliers.
OFFSET
• Retroactively compensate for overtime work at the established overtime premium rate.
• Conduct periodic medical check-ups for workers. Provide adequate rest and suitable medical
assistance to workers suffering from fatigue.
CASE STUDY: SOUTH AFRICA
MNC Incorporated is a medium-size boiler manufacturing company in South Africa. The company
produces steam boilers that are used in process industries. The company is located in a remote
area away from any major cities. As a result, it is difcult for the company to recruit workers with
the necessary skill level. High-skilled workers are reluctant to join the company due to its location
and lack of facilities. Furthermore, the growth of process industries in the country has increased
the demand for MNC’s products. The company is struggling to keep up with demand, but does
not want to turn down orders and lose business to its competitors. In order to accommodate
the increased demand, the company has been increasing the number of hours its workers are
required to work. Though the national law limits working hours per week to 55 hours, including
overtime, the company has been deploying workers for an average of 90 hours per week. This is
almost double the number of allowed working hours. And, due to the strenuous nature of the
work, this excessive overtime has resulted in deterioration of product quality over the past year.
Customers have begun to complain and demand compensation for defective products. The local
authorities have also taken notice of the company’s practices and have issued a warning that any
further violation will result in suspension of the factory’s operating license. The company’s man-
agement must now review its operations to remedy the issue.
3. Management Programs
36 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
A well-implemented ESMS is ultimately about
trained, committed people. How do you make
that happen?
ROLES, RESPONSIBILITIES AND AUTHORITIES TO
IMPLEMENT THE ESMS
First, you need senior management commitment. Senior management
commitment starts with adopting the ESMS policies, but it must go
beyond that. Senior management support is critical to implementing a
sustainable ESMS. It is the responsibility of senior management to lead
the eort. ey don’t have to lead the eort on a day-to-day basis, but they
do need to send a clear message, to all employees at all levels, that this is a
long-term commitment by your company.
Beyond senior management commitment, you need a team that takes
responsibility for the ESMS. is does not need to be a full-time job for
anyone, but senior management needs to ensure realignment of reporting
duties, allocation of appropriate time and authority to carry out the work
involved.
A well-balanced ESMS Team is a prerequisite for meaningful engagement
with your peers and colleagues. It should include knowledgeable profes-
sionals from environment, health and safety, operations or production,
contracts and purchasing, human resources, for example.
In fact, the success of a management system depends on departments that
have traditionally been seen as beyond the reach of environmental and
social issues, such as human resources, production, procurement and main-
tenance. For example, human resources manages training needs related to
the labor aspects; production focuses on the more ecient use of resources
and the reduction of waste; procurement manages the qualications and
performance of suppliers and contractors; and maintenance ensures that the
equipment runs eciently and that spills, leaks and other emergency situa-
tions are minimized.
e ESMS Team should not work in isolation when identifying risks and
impacts, developing improved procedures, designing actions plans, etc. To
be truly eective, the ESMS Team needs to consult with people from all
levels of the company, including supervisors and workers, as they are key
frontline identiers of problems.
5
4
3
2
1
0
All levels of the company
are trained and engaged –
multiple units and workers
as well as managers. E&S
staff has implementation
authority. Management
commitment is reected
in resources devoted to
E&S management and
training.
Multiple units have E&S
responsibilities, and senior
management is involved.
E&S is managed as an
inte- grated system. New
staff receives some E&S
management guidance.
All levels of the company
are involved in aware-
ness training. E&S roles
and responsibilities are
assigned and part of daily
operations. E&S staff is
trained and competent.
E&S roles are dened and
assigned. Each issues is
handled only by one func-
tional area. Some aware-
ness training is provided
at orientation and addi-
tional training is provided
for EHS staff.
No assigned staff with
E&S management respon-
sibilities. Some limited
awareness and E&S roles
and responsibilities start-
ing to get dened. No
systems awareness or
repeatable processes.
No internal awareness
and no formally assigned
responsibility for E&S.
ELEMENT 4
Organizational Capacity
and Competency
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 37
As with the overall management system, the team should be scaled to the size
and complexity of your company. Your organization might not have multiple
departments with distinct roles; maybe a few people cover several functions.
e key is to involve people across the range of functions. If a team already
exists in your company (e.g. re safety team, health and safety committee)
consider building your ESMS Team upon it.
Once the ESMS Team is selected, the team members need to select a team
leader. is is an important role, especially in the beginning. e team leader
needs to set the tone for the group and keep people motivated. All new initia-
tives in a company face hurdles, and developing and implementing an ESMS is
no exception. e team leader needs to help the team overcome the inevitable
hurdles, and should have direct access to senior management.
Take a look at the Toolkit item Roadmap and Time Estimate for
Developing and Implementing an ESMS in the Toolkit for a list
and sequencing of activities to develop and implement an ESMS.
4. Org. Capacity and Competency
38 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
COMMUNICATION AND TRAINING
Now that you have identied the actions to be taken and updated your proce-
dures, you need trained, committed people who follow the ESMS procedures.
is is the end goal of communication and training.
ere are three key steps that build on each other:
1. They need to be aware of the ESMS.
• What is it?
• What are its goals?
• What do I need to do?
2. They need to understand that the ESMS is necessary and will improve
the company.
• How does this help our company?
• How does it help my department?
• What will change?
• What is in it for me?
3. They need to obtain the skills and knowledge to be effective in
their roles.
• What are the new policies and procedures?
• What exactly do I need to do?
• How do I do that?
• What will happen if I don’t do it?
When selecting a
team leader, look
for someone who
has the following
qualities:
• communicator;
• problem-solver;
• project manager;
• pragmatic; and
• respectful to all.
Human
resources
EXAMPLE OF AN ESMS TEAM
Quality
control
Environmental
health & safety
Procurement/
Sourcing
Worker
Representatives
Production
Select a
team leader
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 39
TIP
Effective Communication and Training
Ask yourself if the goal of this specic com-
munication or training module is to build
awareness, to gain commitment and/or give
people the knowledge and skills needed to
implement.
Your ESMS Team needs detailed training to
develop the necessary knowledge and skills. ey
will need to understand the basics of the Plan-Do-
Check-Act cycle and know the nine elements of
an ESMS. is Handbook provides the informa-
tion they will need, but additional help may be
necessary. In addition to the detailed training of
the team, everyone will need to receive awareness
training so there is a shared understanding of the
goals of the ESMS.
e chapters in this Handbook provide an easy way to structure ecient
general training. You can give everybody an overview about what you have
learned here about developing and implementing an ESMS.
You may also need to provide training that is specically related to your Ac-
tion Plan and new operating procedures.
Examine the specic actions and who is going to be involved. is is a quick
way to determine what training will be needed by the various departments
and people in your company. Ask yourself what knowledge and skills do
people need to eectively implement new procedures, carry out allocated
responsibilities and complete the action plan.
AWARENESS COMMITMENT IMPLEMENTATION
Use the Toolkit item Training Plan Worksheet as template and
tie it to your Action Plans and improved procedures.
4. Org. Capacity and Competency
40 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
Even when you have considered all the risks and put
the appropriate management programs in place,
accidents and emergency situations can happen.
Your business is a dynamic operation, and many
things change from day to day – people go in and
out of your workforce, materials and suppliers enter
and exit your supply chain, facilities and equipment
are added to and removed from your production
line. A management system will help to maintain
continuity and consistency throughout these
changes. However, there may be a momentary lapse
or gaps in the system (e.g. someone not properly
trained, someone not following the procedures,
a machine breakdown), or an external force (e.g.
natural disaster) that can lead to an accident or
emergency situation at your facility. While it is not
always possible to prevent such situations, you can
be prepared to respond effectively to prevent and
mitigate any harm to your workers, community and
the environment.
5
4
3
2
1
0
Regular engagement with
local community and gov-
ernment for onsite and
offsite emergency plan.
Formal resource-sharing
agreements with neighbor-
ing companies.
Senior management and
all units and shifts, includ-
ing contract and tempo-
rary workers, participate
in emergency risk assess-
ment, preparedness plan-
ning and mock drills.
Continual improvement.
All onsite and off-site
emergency issues have
been identied and an
effective preparedness
plan is in place. The plan
meets the local regulatory
requirements and the local
industry best practices.
The emergency prepared-
ness plan is in place, but
there is no evidence of
consistent implementa-
tion. Some trainings are
provided to the workers on
emergency requirements.
Emergency management
planning is not effective,
as all emergency risks
have not been identied.
Occasional trainings are
provided to workers.
Very limited emergency
control and personal pro-
tective equipment. No for-
mal plan in place.
ELEMENT 5
Emergency Preparedness
and Response
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 41
e key to eective response is eective preparation. e following steps will
help you to anticipate the possible scenarios and prepare accordingly:
• Identify the areas where accidents and emergency situations may occur, and
communities and individuals that may be impacted. is should begin during
your overall risk and impact assessment, through your process analysis, physical
mapping and consultations with workers, experts and the community.
• Develop response procedures for each identied emergency situation that clearly
explain what actions need to be taken. ese need to be detailed clearly for
everyone in your company to understand what he or she needs to do.
• Provide the necessary equipment and resources to eectively implement the
response plans. A stockpile of re extinguishers does not put out res, unless
people can eectively nd and use them when needed. ink about equipment
that is easy for people to use and is located where it can be immediately accessed
during accidents and emergencies.
• Assign responsibilities so that each activity has people responsible for carrying
it out. Also designate people who will routinely analyze how well the system is
working and update the risk assessment and plans.
• Communicate so that everyone in your company understands the importance
of the emergency preparedness and response system and is encouraged to help
monitor and improve its eectiveness. Also include people in the community
who may be aected.
• Provide periodic training so that everyone in your company has an overview
of the system, and knows the response plans. Don’t just lecture about what
to do – ask for and obtaininput on what needs to be addressed and what can
be improved. Even with the most detailed procedures and plans, people will
need to exercise individual judgment and adapt to quickly changing situations.
is is more likely to happen if you engage people in all aspects of the system
beforehand.
• Work with government agencies and community groups to identify areas where
you can collaborate to respond eectively to internal and external situations.
• Conduct periodic checks and drills to test how well the system is working and
to re-assess the risks to reect changing conditions. Incorporate your ndings to
continually improve your system.
• Remember, it is essential that the emergency response plan be site specic.
Even if you have similar operations at two dierent sites, it does not mean that
the same emergency plan would be eective at both locations. An emergency
response plan at each site should be independently reviewed for its suitability
and eectiveness.
Look at the Sample Fire Response Procedure and Sample Chemical
Spill Response Procedure Flowchart for examples.
5. Emerg. Preparedness and Response
42 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
An Emergency Preparedness and Response Plan
should include:
• identication of potential emergencies based on
hazard assessment;
• procedures to respond to the identied emergency
situations;
• procedures to shut down equipment;
• procedures to contain and limit pollution;
• procedures for decontamination;
• procedures for rescue and evacuation, including a
designated meeting place outside the facility;
• location of alarms and schedule of maintenance;
• list and location of equipment and facilities for
employees responsible for responding to the
emergency (re-ghting equipment, spill response
equipment, personal protection equipment for the
emergency response teams, rst aid kits and stations);
• protocols for the use of the emergency equipment
and facilities;
• schedule for periodic inspection, testing and
maintenance of emergency equipment;
• clear identication of evacuation routes and
meeting points;
• schedule of trainings (drills), including with local
emergency response services (re ghters);
• procedures for emergency drills;
• emergency contacts and communication protocols,
including with affected communities when necessary,
and procedures for interaction with the government
authorities;
• procedures for periodic review and update of
emergency response plans.
5. Emerg. Preparedness and Response
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 43
Common OHS Hazards and Emergency Situations
in the Metal Products Manufacturing Industry
5. Emerg. Preparedness and Response
Occupational Health and Safety (OHS) hazards in the workplace can be
divided into ve categories: physical, chemical, biological, ergonomic and
radiological.
You should identify the specic hazards that are relevant to your company’s
operations during your risk assessment, using methodologies such as job safety
reviews or job hazard analyses. e results of these analyses and the tasks
required to mitigate the identied hazards should be incorporated into action
plans, which also stipulate the assigned responsible sta and expected timelines
for completion.
Your management program should seek to rst avoid negative impacts from
each hazard, by eliminating or substituting the equipment, material, or work
practice that is causing the hazard. If it is not possible to eliminate the hazard,
you should seek to minimize its impacts by instituting engineering controls
(e.g. by installing machine guards or active ventilation) and administrative
controls (e.g. job rotation, clear work instructions or warning signage). You
should also provide technically appropriate personal protective equipment
(PPE) and train your personnel on the appropriate use and maintenance of
supplied PPE.
OHS emergency situations often occur because of gaps in a company’s man-
agement system. us, even though the hazards may seem to be very dierent,
such as slips and falls on spilled liquids vs. exposure to radiation, they are often
the result of the same root cause – ineective implementation of the ESMS.
e tables below describe common workplace hazards and their associated po-
tential impacts. ey also illustrate how inadequate implementation of any of
the 9 ESMS elements can be the root cause of such situations. e examples
below are not an exhaustive list of root causes. You should identify gaps in your
own system to determine potential root causes of problems during your risk
assessment.
44 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
5. Emerg. Preparedness and Response
PHYSICAL HAZARDS
Examples Potential Impacts
• Slipping on spilled liquids (e.g. fuel or
lubricants)
• Falling from heights (e.g. from a ladder or
work platform)
• Collision with moving items (e.g. cranes,
vehicles or forklifts)
• Interacting with improperly enclosed, un-
guarded or moving machines (e.g. hydrau-
lic forming presses, drill presses, or metal
cutting tools)
• Being struck by ying metallic particles
• Exposure to high noise levels
• Exposure to extreme temperatures
• Exposure to welding arcs
• Touching exposed, damaged or improperly
grounded electrical wires
• Improper grounding of electrical wires
• Ignition of metallic dust or other combus-
tible materials
• Explosion of improperly stored oxygen,
nitrogen, acetylene or argon gas cylinders
(i.e. no protection from heat and sunlight
or improper fastening arrangement)
• Sprains and strains
• Fractures
• Cuts, abrasions, puncture wounds
• Traumatic amputation
• Eye injuries
• Hearing threshold shifts and loss
• Heat stress, dehydration, heat stroke
• Electrocution
• Asphyxiation and burnings in case of re
• Death
Fires or explosions from ignited combustible
materials can lead to massive loss of life and
destruction of property.
Potential Root Causes
Management Program:
• Lack of, inadequate, or
improperly implemented
safety procedures
Organizational Capacity and
Competency:
• Insufcient worker training
about hazards
• Failure to nominate respon-
sible party for managing
hazards
Emergency Preparedness and
Response:
• Lack of or inadequate
emergency preparedness
and response plan
• Insufcient mock drills
• Contract and temporary
workers not included in
emergency planning
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 45
5. Emerg. Preparedness and Response
CHEMICAL HAZARDS
Examples Potential Impacts
• Skin contact or inhalation of toxic and
carcinogenic substances contained in me-
tallic fumes, metal working uids, metal
cleaning solvents, or priming and painting
compounds
• Ignition of ammable liquids and gases
• Skin irritation and burns
• Irritation of eyes, nose and throat
• Breathing difculty
• Intoxication
• Damage to internal organs
• Damage to nervous, immune, and repro-
ductive systems
• Cancer
• Asphyxiation and/or burning in case of re
• Death
Fires from ignited ammable liquids or gases
may have disastrous impacts on worker safety
and your business.
Potential Root Causes
Identication of Risks and
Impacts:
• Incomplete risk assess-
ment of chemicals and
raw materials used in the
facility
• Lack of awareness of
chemical risks in the
workplaces
Management Program:
• Use of incompatible or
damaged storage containers
• Uninformed or incorrect
labeling
• Insufcient monitoring of
allowable chemical concen-
trations in the workplace
• Inadequate PPE
Emergency Preparedness and
Response:
• Lack of or incomplete
emergency response
planning
• Poorly executed emergency
detection, alarms, evacua-
tion, and re suppression
systems
• Insufcient worker training
and mock drills
• Lack of communication or
awareness of individual
responsibilities during
emergencies.
46 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
BIOLOGICAL HAZARDS
Examples Potential Impacts
• Exposure to bodily uids that may carry pathogens
(e.g. when treating an injured worker)
• Exposure to pathogens due to lack of hygiene in
canteen facilities and amongst food handlers
• Debilitating illnesses among
workers and even death
Potential Root Causes
Policy:
• Lack of, inadequate or
improperly implemented
safety policies and proce-
dures
Emergency Preparedness and
Response:
• Failure to nominate emergency
response brigades
• Insufcient worker training on
rst aid response
Monitoring and Review:
• Failure to monitor and
review hygiene prac-
tices and improve them
as needed
5. Emerg. Preparedness and Response
ERGONOMIC HAZARDS
Examples Potential Impacts
• Heavy lifting or improper lifting techniques
• Repetitive motions
• Improperly aligned work stations
• Insufcient and restricted work space
• Standing for extended periods of time
• Continued forceful exertions
• Inadequate lighting
• Strains and sprains to muscles and connec-
tive tissues causing pain, inammation,
numbness, or loss of muscle function
• Lower back injuries
• Permanent disabilities
• Eyestrain
Potential Root Causes
Identication of Risks and
Impacts:
• Incomplete risk assess-
ment of working areas
• Lack of awareness of
ergonomic risks in the
workplaces
Management Program:
• Insufcient number of staff
to perform duties (e.g.
heavy lifting)
• Insufcient breaks
• Inadequate PPE
• Inadequate medical care
for staff
Organizational Capacity and
Competency:
• Decient worker training
on proper techniques for
lifting or performing duties
• Failure to nominate respon-
sible party for managing
ergonomic hazards
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 47
5. Emerg. Preparedness and Response
In addition to emergencies that may result from workplace hazards, all
workplaces are also vulnerable to other types of accidents and emergencies,
including manmade or natural disasters. Some of these situations may
be preventable, such as res resulting from improperly stored ammable
chemicals, while other may not be, such as an earthquake.
e following list includes common types of emergencies, all of which can
result in signicant worker injury or death, as well as disruption of operations,
destruction of property, and severe nancial losses.
During your risk assessment, you should identify the emergencies that are
most likely to occur in your area and create a comprehensive emergency
preparedness plan so you can respond properly to the unplanned event and
minimize damage to your company and workers in case of an emergency.
Possible manmade or natural disasters include:
• storms, including tornados, typhoons, and hurricanes (many can result in
ooding);
• ooding, earthquakes and associated tsunamis, and volcanic eruptions;
• local and regional res;
• explosions, including accidental, military or terrorism;
• civil unrest; and
• chemical spill or release of hazardous substances due to ruptured containers,
transport accidents, earthquakes and other natural disasters.
Emergencies
Caused by
External Events
RADIOLOGICAL HAZARDS
Examples Potential Impacts
• Exposure to radiation (e.g. x-ray from
non-invasive testing, UV radiation from
welding)
• Continued exposure to radiation from
electronic equipment
• Exposure to laser light
• Radiation sickness
• Cancer
• Welder’s eye
• Skin cancer
• Eye injuries
Potential Root Causes
Identication of Risks and
Impacts:
• Lack of awareness of
radiation sources and
associated risks in the
company
Management Program:
• Use of non-certied equip-
ment and radiation sources
• Use of expired radiation
licenses
• Decient procedures re-
garding allowable exposure
limits and worker exposure
periods
Monitoring and Reviewt:
• Inadequate monitoring
of worker exposure to
radiation sources
48 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
FINANCIAL
COMMUNITY
COMPANY
ACTIVIST
GROUPS
GOVERNMENT
TRADE UNIONS/
WORKER
ASSOCIATIONS
SUPPLIERS/
CONTRACTORS
STOCKHOLDERS/
OWNERS
AFFECTED
COMMUNITIES
WORKERS
CONSUMERS
NGOs
Stakeholder Engagement
Your company may have an impact on the lives
of many people and organizations. All of these
people and organizations are your stakeholders
- they have a stake in your company’s nancial,
environmental and social performance.
Look at the diagram below and think about how your company interacts
with each group. Your relationship with each group is dierent, and you
need to adapt the way you engage with each of them to mitigate risks to
your business.
Systematically engaging with aected communities in the identication
and management of the impacts that negatively aect them contributes
to building trust, credibility and local support. Engaging with them also
provides the opportunity to highlight the positive aspects of the company’s
presence. is lowers the risk of anti-company sentiments that could lead
to costly litigation or disruption of company operations.
5
4
3
2
1
0
Stakeholder engagement
is part of regular activities.
Awareness and engage-
ment at senior levels. Flu-
ent and inclusive commu-
nication and consultation
process with stakeholders.
Multiple and ongoing
public consultation and
participation in a cultur-
ally appropriate manner.
Stakeholder feedback
is actively considered.
Reporting to communities
and effective grievance
mechanism is evidenced
by formal records.
Stakeholders have been
identied and engaged
in several events with
effective dialogue. Some
procedures and assigned
responsibility for engaging
with stakeholders.
Some public events, lim-
ited ongoing engagement
process. Sporadic and
selective responses
when approached by
stakeholders.
Limited channels in place.
A few meetings and
discussions, but not an
ongoing process yet.
Little or no transparency
with stakeholders.
ELEMENT 6
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 49
Other stakeholders such as activists and NGOs may not be directly aected
by your operations but may have an interest in what you do. Keeping these
groups informed and maintaining an open communication channel may lower
the risk of negative campaigns that could aect your company’s reputation.
MAPPING YOUR STAKEHOLDERS
e rst step in building a relationship with your stakeholders is to identify
them. To start, look back at your risk assessment and the areas of potential
negative impacts and identify who would be directly or indirectly impacted.
Once you have identied your stakeholders, you should prioritize the dier-
ent groups based on the nature and severity of the impacts, and the ability of
these groups to inuence your business. Engagement should be stronger and
more frequent with those groups that are more severely aected, as well as with
those that have a greater ability to inuence your business.
Also, as you identify your stakeholders and the issues that may aect or interest
them, you can tailor your communication material and methods to eectively
engage with each of them.
Use the Toolkit item Stakeholder Map and Impact
Zoning Tool for Affected Communities to get started.
INTERNAL AND EXTERNAL STAKEHOLDERS
Workers are an important internal stakeholder group. They also
need to be involved in the identication of risks that affect them
and be consulted when developing action plans and procedures.
However, the methods of engagement with them will differ from
those used for external stakeholders.
6. Stakeholder Engagement
50 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
For effective
consultation
with affected
communities :
• Start early;
• Disclose meaningful
and accurate
information;
• Use culturally
appropriate means to
reach them;
• Provide opportunities
for two-way dialogue ;
• Document to keep
track of issues raised;
and
• Report back on how
their input has been
used and considered
DEVELOPING A STAKEHOLDER ENGAGEMENT PLAN
After mapping your stakeholders, the next step is to develop a plan for how
to engage with the groups that you have identied. Your stakeholder engage-
ment plan can be simple. But it is important to be proactive and to address key
environmental and social concerns.
At a minimum, even if your company does not have adverse impacts on com-
munities or other stakeholders, you should always implement a procedure to
receive communications from the public and accordingly adjust your man-
agement program (see Element 7, External Communications and Grievance
Mechanisms).
If it is determined that there are aected communities, you need to imple-
ment a Grievance Mechanism (see Element 7, External Communications and
Grievance Mechanisms) and actively engage them in consultation, regularly
disclosing clear and meaningful information on both your impacts and poten-
tial benets, and providing communities with opportunities to express their
concerns and suggestions.
In the case of potentially signicant adverse impacts to individuals and com-
munities, you should engage them in a process of Informed Consultation
and Participation (ICP). Compared to a consultation process, an ICP should
ensure a more in-depth exchange of information and a higher level of partici-
pation from aected stakeholders in decision-making, so that their proposed
mitigation measures are incorporated into the company’s action plan.
Finally, you should periodically report to aected stakeholders on the actions
your company is putting in place to address the issues identied through
the engagement process (see Element 8, Ongoing Reporting to Aected
Communities).
Regular communication with the various stakeholder groups is an excel-
lent way for you to understand how company operations aect them and to
get early warnings of potential problems. In all your eorts to reach out to
stakeholders, ensure that you do so early on – relationship-building takes time.
Don’t wait until a crisis arises to act, as it will be more dicult without those
relationships in place to manage the problem.
Use the Toolkit item Stakeholder Engagement
Plan Worksheet to record how you will engage
with the important stakeholder groups.
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 51
TIP
Effective Stakeholder Engagement
• Be strategic and prioritize which stakeholders to approach –
you may not have the resources to engage them all at once.
• Update your stakeholder map regularly and in the case of
signicant events (e.g., changes to your business, government
elections, natural disasters, etc.).
• Be aware of what issues are important to each group.
• If you are dealing with a representative for the group, make
sure that he/she legitimately represents the interests of the af-
fected groups and communities.
• Engage with stakeholders in their own communities and places
where they feel comfortable.
• Reach out to vulnerable and marginalized groups.
• Keep a record of questions, comments and suggestions. Records
provide important information that should be used to adapt
your Action Plans and improve your ESMS.
• Recognize that your employees are a good link to stakeholders
in the “outside world.”
• Be prepared to respond to stakeholders, and do not generate
expectations that cannot or will not be fullled.
DEFINITIONS
Stakeholder
Any person or organization that has an interest in or is affected by
your company
Affected
Communitites
People or communities who are subject to company-related ad-
verse impacts on their environment, infrastructure, way of life,
personal safety, health or livelihood.
6. Stakeholder Engagement
For more information on how to develop and implement a Stakeholder
Engagement Plan, refer to the Good Practice Handbook “Stakeholder
Engagement,” IFC (2007).
52 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
If your company has social and environmental
impacts in the community, inquiries, concerns and
complaints are bound to arise. How you respond
to and manage these issues will have signicant
implications for how your business is perceived and,
possibly, whether or not it succeeds.
EXTERNAL COMMUNICATIONS
Even if aected communities per se are not identied, you should always
establish and maintain a publicly available and easily accessible channel for
stakeholders to contact you (e.g., phone number, website, email address, etc.).
External stakeholders can provide valuable information, such as suggestions
on product improvement, advance warning in critical situations, feedback
on interactions with your employees, and/or comments from regulators,
NGOs and individuals regarding your company’s environmental and social
performance.
e procedure for external communication should include methods to (i)
receive, register and validate external communications and requests for infor-
mation from the public; (ii) screen and assess the importance of the issue raised
and determine how to address it; (iii) provide, track, document and publish
responses; and (iv) adjust the management program when appropriate.
GRIEVANCE MECHANISMS
e purpose of a grievance mechanism is to establish a way for individuals,
groups or communities aected by your business to contact you if they have an
inquiry, a concern or a formal complaint.
Proactive and responsive
external communication
and grievance mechanism.
Stakeholders are consulted
on ESMS effectiveness
and are part of the regular
review process.
Effective grievance mecha-
nism is evidenced by for-
mal records. There is rou-
tine review of the records
and the effectiveness of
the program.
Grievance mechanism is
fully implemented; how-
ever, there is not enough
evidence of its effective-
ness. No tracking of inter-
nal or external awareness;
limited tracking of cases.
Procedures and assigned
responsibilities for receiv-
ing and handling com-
plaints. Awareness is
limited to those directly
handling the complaints.
Some basic procedures
for receiving complaints.
Responsibility limited to
one person or unit.
No mechanism in place.
5
4
3
2
1
0
ELEMENT 7
External Communications
and Grievance Mechanisms
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 53
7. Ext. Communication and Grievance
In practice, a grievance mechanism should:
• Establish a way for people to contact you – openly or anonymously – to
pose their questions, to express concerns or to le a complaint. Examples
are suggestion boxes, a toll-free telephone hotline, an email address, and
regular meetings arranged to discuss particular problem areas.
• Assign a person or team in your company to be responsible for receiving,
registering and processing all grievances.
• Establish procedures to register, screen, categorize, investigate and deter-
mine resolution and redress options.
• Establish a system to communicate decisions taken and progress on pend-
ing actions. It is important that people know when they can expect a
response.
Not all complaints can be resolved in the same way. Simpler issues, such as a
company truck running over chickens in the road, might be dealt with by the
same team responsible for registering the complaint. More complex problems,
such as allegations of widespread groundwater contamination, might require
immediate intervention by senior managers and more dedicated resources for
investigating, documenting and reporting. For complex and recurring prob-
lems, consider reaching out to third-party facilitators that can act as indepen-
dent mediators.
e more serious the claim is, the more indepen-
dent the mechanism should be to determine the
resolution and options for redress.
e most important thing is to make sure the griev-
ance mechanism is accessible and trusted. Tailor it
for the local community so that it is easy for them
to raise concerns. is requirement mandates
having the right people leading this eort inside
your company. e grievance mechanism must be
accessible at no cost and without retribution to the
party that originated the complaint and should not
impede access to judicial or administrative remedies.
Don’t underestimate the value of a well-implement-
ed grievance mechanism. e information you re-
ceive can act as an early-warning system before the
problem becomes too costly and time-consuming
to address.
TIP
Implementing a Grievance Mechanism
• Scale it to t the level and complexity
of social and environmental risks and
impacts identied in your company.
• Design the process to be easily un-
derstandable, accessible, trusted and
culturally appropriate.
• Publicize the availability of the griev-
ance procedure so people know where
to go and whom to approach.
• Commit to a response time and keep
to it as this will increase transparency
and a sense of “fair process.”
• Keep records of each step to create a
“paper trail.”
54 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
TIP
A Grievance Mechanism is
UNDERSTANDABLE AND TRUSTED when:
• affected communities understand the procedure to handle a
complaint;
• people are aware of the expected response time; and
• condentiality of the person raising the complaint is protected.
CULTURALLY APPROPRIATE AND ACCESSIBLE when:
• claims can be presented in the local language;
• technology required to present a claim is commonly used (e.g.,
paper, text messaging, internet); and
• illiterate persons can present verbal complaints.
AT NO COST when:
• people don’t need to travel long distances to present a claim; and
• the company covers the costs of third party facilitation.
Look at the Toolkit items Checklist for an Eective Grievance
Mechanism and Grievances Log to get started.
7. Ext. Communication and Grievance
For more information on how to develop and implement a Grievance
Mechanism, refer to the Good Practice Note “Addressing Grievances from
Project-Aected Communities,” IFC (2009), and the Advisory Note “A
Guide to Designing and Implementing Grievance Mechanisms for Develop-
ment Projects,” CAO (2008).
Company team
Multistakeholder group
including representatives
of Affected Communities,
NGOs, government
Independent
mediator
Seriousness
of the claim
Independence of
the mechanism
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 55
Affected communities will want to know what
actions your company has put in place to resolve
the issues identied when engaging with them.
Keeping aected communities informed of what you are doing is a critical
element for building and maintaining a good relationship. If people know
when they will receive an update, it helps to build trust. It can also reduce the
amount of time you spend responding to questions.
e frequency of this communication will be proportional to the scale of stake-
holders’ concerns, but it should be at least annual. If your company’s activities
change or new environmental and social risks emerge, you do need to contact
stakeholders outside of the regular schedule to discuss these changes.
You can also decide to
report back to the wider
public on your progress
in meeting your commit-
ments to avoid, reduce
and mitigate any negative
environmental or social
impacts from your com-
pany’s activities. Sustain-
ability reporting initiatives,
guidelines, including
sector-specic guidelines,
and good practices are also
rapidly emerging in this
area. e most notable
is the Global Reporting
Initiative (GRI).
Affected communities’
issues and concerns are
proactively addressed.
There is ongoing com-
munication to avoid risks
and impacts before new
projects as well as to
address existing issues.
Reporting to affected
communities is regu-
larly implemented and
evidenced in documen-
tation. Key units are
involved in the review
of the key issues.
When applicable, con-
sultation processes have
been implemented.
External consultants are
involved as required. No
ongoing review.
Procedures in place
for reporting, usually
assigned to E&S staff.
Primarily reactive.
Some basic communica-
tions with affected com-
munities, mostly limited
to meetings.
No reporting.
5
4
3
2
1
0
TIP
Ongoing Communication
• Provide an immediate update if new envi-
ronmental or social risks emerge.
• Report progress on implementation of
your commitments.
• Report monitoring results on issues that
interest the community.
• Use the opportunity to communicate the
benets generated by your company.
• Translate information into local languages
and easily understandable formats.
• Try to maintain continuity in who deals
with the community.
• Involve your employees as communication
links to the community.
• Consider conducting a stakeholder survey
to learn how your company is perceived.
Look at the Toolkit item Reporting to Aected Communities for
examples of formats and venues you can use.
ELEMENT 8
Ongoing Reporting to
Affected Communities
56 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
DO
PLAN
CHECK
ACT
Monitoring is the CHECK
step of the PDCA cycle
Review is the ACT
step of the PDCA cycle
We’ve talked about the relationship between
your ESMS and the Plan-Do-Check-Act cycle of
continual improvement. Monitoring and review
are critical, because this is how you check and
adjust the system.
So far, you’ve formed or assigned a team to
lead the effort. You have developed your ESMS
and started to implement your action plans in
response to the risks and impacts you identied.
You’ve started to train people. The next step
is to monitor the effectiveness of your ESMS
and your action plans and make the necessary
adjustments.
5
4
3
2
1
0
Robust system of continual
learning and improvement.
Senior management receives
periodic reports about E&S
performance and progress
toward E&S objectives and
targets. All key project deci-
sions consider E&S.
Monitoring, supervising and
auditing activities are inte-
grated and included in man-
agement review. Includes
consultation with workers,
customers and suppliers.
E&S objectives and targets
are included in job descrip-
tions and performance
reviews.
Routine review of monitor-
ing and supervision activi-
ties, including participation
of workers. Corrective
actions routinely imple-
mented. An E&S internal
audit plan is in place.
Key E&S monitoring plans in
place, with inspection and
supervision activities. Pri-
marily reactive and guided
by external experts, custom-
ers and investors.
Few monitoring plans to sat-
isfy regulatory requirements.
No formal review activities.
No systems awareness or
repeatable processes
No monitoring of E&S
performance.
ELEMENT 9
Monitoring and Review
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 57
INDICATORS
A key aspect of monitoring is dening relevant indicators. ese are quan-
titative or qualitative measures of progress against set goals. Some indicators
might focus on performance, evaluated against the criteria dened in your
environmental and social policy.
Some examples of key performance indicators could be:
• energy consumption;
• volume of solid waste disposal;
• water consumption;
• liquid euents discharge;
• emissions to air;
• noise and vibration levels;
• work zone air quality;
• accidents (injuries, ill-health, property damage), incidents and near misses;
• lost work time injury frequency, incidence, and severity rates
• emergency response incidents;
• average working hours and wages paid;
• wage levels;
• incidences of child labor;
• incidences of disciplinary and discrimination complaints; and
• employee demographics matching access to training, jobs, and wages.
9. Monitoring and Review
TIP
Monitoring measures intent, implementation and effectiveness
Intent:
1. Are the nine elements of the ESMS in place?
Implementation:
2. Are the action plans being carried out?
3. Are procedures being followed?
Effectiveness:
4. Are you in compliance with laws and regulations?
5. Are you making progress toward your overall objectives
and targets?
6. How is the environmental and social performance of the
company in general?
58 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
You can also use this information when reporting to a wider public on your
ESMS performance. When selecting your key performance indicators, you may
refer to voluntary guidelines such as the Global Reporting Initiative, which
provides a list of indicators for various industries.
Other indicators can look at the processes or inputs that you use to try to
achieve performance.
For example, in your action plan, you might have included worker training as
a necessary step to raise awareness among workers about OHS, so that they
can help to identify and address key risks and hazards. In this case, you might
evaluate your progress against the action plan by tracking the percentage of
workers who have been trained, or the percentage of workers who can correctly
describe the risk analysis procedure.
Some examples of process indicators include:
• procedures in place for chemical, fuel and hazardous waste handling,
storage, and disposal;
• processes analyzing the ecient use of energy and materials;
• percentage of workers who can explain the grievance mechanism;
• percentage of workers who can explain the health and safety procedures;
• percentage of workers trained on labor standards requirements; and
• communications from stakeholders.
It is helpful to have a mix of performance and process indicators, to get a
deeper understanding of whether you are measuring the appropriate things and
whether you are taking the appropriate actions. For example, a performance in-
dicator such as “zero incidences of child labor” does not tell the full story: Was
this the result of eective procedures and training or was the system inadequate
in identifying and recording incidences?
Measuring and
Improving
Remember, you
can’t improve what
you don’t measure.
Look at the Monitoring Plans in the Toolkit for more examples
of key indicators common in the metal products manufacturing
industry
9. Monitoring and Review
For environmental and OHS performance indicators and benchmarks
relevant to your industry, consult the WBG EHS Guidelines at www.ifc.
org/sustainability
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 59
THE BASICS OF MONITORING
Visual observation
physical walk-throughs of
your facility and surround-
ing land. Examples of what
you might observe: slip, trip,
and fall hazards, improp-
erly guarded machinery,
warning signs, re detection,
alarm and ghting equip-
ment, use of PPE, storage of
hazardous materials, waste
segregation and treatment,
facility ambient temperature,
raised platforms, worker and
manager body language and
interactions.
Interviews
consultations with workers,
managers and external stake-
holders. Examples of topics
you might discuss: Do workers
and managers understand
the policies and procedures?
How are they impacted? Are
there ideas for improvement?
Do workers feel comfortable
ling complaints? How are
external stakeholders
impacted by the company?
Are there ideas for improve-
ment? Do external stakehold-
ers feel comfortable ling
complaints?
Measuring and
testing
checking using equipment
that is properly calibrated.
Examples of what you might
check: air emissions, waste-
water quality, concentration
of airborne metal nes, noise
levels, quality of drinking
water.
Document review
looking through documents
and records. Examples of
what you might review: busi-
ness permits and licenses,
energy and water bills, health
and safety plan, OHS records,
OHS corrective actions plans
and status of corrective
actions, equipment mainte-
nance logs, inspection records,
complaint logs, wage slips,
time cards, policies and proce-
dures, training records.
Look at the Toolkit item Auditing Guidance for guidelines
on how to conduct an audit.
9. Monitoring and Review
60 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
MEASURING AND IMPROVING YOUR ESMS
While your Action Plan monitoring looks at whether corrective actions are
being implemented and are achieving the intended results, your ESMS moni-
toring is looking at the maturity of your system development and implementa-
tion. e Action Plan lists new actions you are taking to address risks. But for
the new actions to be sustainable, you also need to improve your ESMS. e
two need to be linked.
is Handbook’s companion publication ESMS Self-Assessment and Improve-
ment Guide provides you with a practical tool to monitor the maturity of your
ESMS. For each of the nine ESMS elements, we provide self-assessment ques-
tions that show you the level of your ESMS development and implementation
on a scale of 0 to 5 (5 is the highest). Conducting the ESMS self-assessment is
an important rst step that enables you to see where you stand now. e results
form the basis of your ESMS Improvement Plan. e ESMS self-assessment
responses should be based on Visual Observation, Measuring or Testing,
Document Review and Interviews.
Let’s take another look at the nine elements of the ESMS and maturity ratings.
Monitoring and auditing are words that are often
used interchangeably, which can be confusing.
Auditing is a formal, on-site evaluation against a
specic set of criteria. Audits can be conducted
internally by your own staff or by outside parties.
Monitoring is an umbrella term that includes various
methods for evaluating performance. These may
include: visual observation, measuring and testing,
questionnaires, surveys, interviews with employees
and external stakeholders, and document review.
It is important to design your monitoring program
to obtain qualitative and quantitative information.
It is also important that workers and managers are
monitoring the workplace on an on going basis.
9. Monitoring and Review
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 61
Policy
Identication of
Risks and Impacts
Management
Programs
Organizational
Capacity and
Competency
Emergency
Preparedness and
Response
Stakeholder
Engagement
External
Communications
and Grievance
Mechanisms
Ongoing Reporting
to Affected
Communities
Monitoring and
Review
5
Mature system implemented internally and with key supply chain partners – continual
improvement embedded in operations
4
Systems well-developed and implemented internally – routine improvement projects
3
Systems approach adopted, but development and implementation is inconsistent -
improvement sporadic
2
Limited system development with sporadic implementation – primarily reactive
1
Little systems awareness or repeatable processes
0
No systems awareness or repeatable processes
LINKING YOUR ACTION PLAN AND ESMS IMPROVEMENT PLAN
It is important to understand the link between the Action Plan and the ESMS Improvement Plan. e
Action Plan lists specic projects and activities. e ESMS Improvement Plan is about making system
improvements needed to support the activities and to make the necessary changes in how the company
operates.
Improving environmental and social performance and integrating it into your routine business operations
takes time. e improvement plan for your ESMS needs to be practical. It needs to be designed with
the understanding that people have their core operating responsibilities in your company. You cannot
improve everything at once. e ESMS Team plays the critical role of leading the improvement eort.
Prioritizing what to work on rst is an important job for the team in coordination with senior manage-
ment. e ESMS Self-Assessment and Improvement Guide will help you to get started.
Purpose of Action Plan and ESMS
Improvement Plan
Action Plan: specic actions to correct
environmental, labor and community
problems and remediate negative impacts
ESMS Improvement Plan: steps targeted to
continually improve the management system to
support activities in the Action Plan
62 Section III: Practical Guidelines for Developing and Implementing your Environmental and Social Management System
CONDUCTING AN EFFECTIVE MANAGEMENT REVIEW
e purpose of the management review is to routinely involve senior manage-
ment in evaluating the development and implementation of the ESMS. e
management review is led by the ESMS Team. In the beginning, we recom-
mend conducting a management review every three to six months. Once the
ESMS is well-established, once a year is usually ne. It is important to keep a
written record (called minutes) during the meeting of the key topics discussed
and the decisions made. e minutes should be kept in a central log.
For the ESMS Team, the management review is an important opportunity to
keep senior management involved. Remember, the sustainability of the pro-
gram requires ongoing commitment from senior management.
Typical Agenda for a Management Review:
• Review progress on Action Plan
• Review progress on ESMS Improvement Plan
• Review compliance with environmental and labor
laws and regulations
• Review progress on environmental and social
performance
• Discuss possible adjustments in risk assessment
• Prioritize activities for next three, six and 12 months
• Review and approve needed resources by senior
management
9. Monitoring and Review
Version 1.2 April 15, 2015 ESMS Implementation Handbook - Metal Products Manufacturing 63
1. Canadian Centre for Occupational Health and Safety. 2015. “OSH Answers Fact Sheets:
Trichloroethylene.” Last updated April 20, 2015.
http://www.ccohs.ca/oshanswers/chemicals/chem_proles/trichloroethylene.html.
2. Centers for Disease Control and Prevention. 2014. “Workplace Safety and Health Topics:
Metalworking Fluids.” Last updated August 16, 2013.
http://www.cdc.gov/niosh/topics/metalworking/.
3. Centers for Disease Control and Prevention. 2014. “Workplace Safety and Health Topics:
Welding and Manganese: Potential Neaurologic Eects.” Last updated May 29, 2014
http://www.cdc.gov/niosh/topics/welding/.
4. Federal Emergency Management Agency (FEMA). 2012. “Coee Break Training – Fire
Protection Series: Portable Extinguishers: Overview of “Class D” Agents.” FP-2012-34.
5. Je Becker, “Improving Metal Fabricating and Coating Energy Eciencies.” (presented at
the 2012 Paint and Powder Coating Expo, March 15, 2012).
6. National Resources Defense Council. 2010. “Congress Must Protect People from Toxic
Chemicals Known to Cause Harm: Tricholoroethylene (TCE).”
7. UK Health and Safety Executive. “Illness caused by welding fume and gases.”
http://www.hse.gov.uk/welding/illness.htm.
8. US Department of Labor, Occupational Safety and Health Administration. 2013.
“OSHA FactSheet: Controlling Hazardous Fume and Gases during Welding.”
9. US Department of Labor, Occupational Safety and Health Administration.
“Metalworking Fluids: Safety and Health Best Practices Manual.”
https://www.osha.gov/SLTC/metalworkinguids/metalworkinguids_manual.html.
10. US Department of Labor, Occupational Safety and Health Administration.2014.
“Combustible Dust in Industry: Preventing and Mitigating the Eects of Fire and
Explosions.” Last updated November 12, 2014.
https://www.osha.gov/dts/shib/shib073105.html.
11. US Department of Labor, Occupational Safety and Health Administration 2014.
“Combustible Dust: An Explosion Hazard.”
https://www.osha.gov/dsg/combustibledust/.
12. OSHA. www.osha.gov
Additional References Consulted
Address:
2121 Pennsylvania Avenue, NW
Washington, DC 20433 USA
Tel. 1-202-473-3800
www.ifc.org/sustainability
Copyright
The material in this publication is copyrighted. IFC encourages the dissemination of
the content for educational purposes. Content from thispublication may be used freely
without prior permission, provided that clear attribution is given to IFC and that content
is not used for commercial purposes.
March 2015
