ISR /
EH&SMS Manual /
Effective Date: 05/01/12
SUBJECT:
Environmental, Health and Safety Management System Manual / Issue: 1.0
Page: 1 of 1

Environmental, Health and Safety (EH&S) Management System Manual

Table of Contents

1 Introduction 3

2 Reference Documents 3

3 Definitions 3

4 Environmental, Health and Safety Management System Requirements 4

4.1 General requirements (ISO 14001 4.1, R2 1.0) 4

4.2 Environmental, Health and Safety Policy (ISO 14001 4.2, R2 1.0) 5

4.3 Planning 5

4.3.1 Environmental aspects (ISO 14001 4.3.1, R2 1.0) 5

4.3.2 Legal and other requirements (ISO 14001 4.3.2, R2 3.0) 5

4.3.3 Objectives, targets and programs (ISO 14001 4.3.3, R2 1.0) 6

4.4 Implementation and Operation 7

4.4.1 Resources, Roles, Responsibility and Authority (ISO 14001 4.4.1, R2 1.0) 7

4.4.2 Competence, Training and Awareness (ISO 14001 4.4.2, R2 1.0) 7

4.4.3 Communication (ISO 14001 4.4.3, R2 1.0) 8

4.4.4 Documentation (ISO 14001 4.4.4, R2 13.0) 8

4.4.5 Control of documents (ISO 14001 4.4.5, R2 13.0) 9

4.4.6 Operational Control (ISO 14001 4.4.6, R2 1.0) 9

4.4.6.1 On-Site Health and Safety (R2 4.0) 10

4.4.6.2 Hierarchy of Responsible Management Strategies (R2 2.0) 12

4.4.6.3 Focus Materials Management and Accountability for Downstream Recycling Chain (R2 5.0) 13

4.4.6.4 Reusable Equipment and Components (R2 6.0) 13

4.4.6.5 Tracking Throughput (R2 7.0) 15

4.4.6.6 Data Destruction (R2 8.0) 15

4.4.6.7 Storage (R2 9.0) 16

4.4.6.8 Facility Security (R2 10.0) 16

4.4.6.9 Insurance, Closure Plan and Financial Responsibility (R2 11.0) 16

4.4.6.10 Transport (R2 12.0) 17

4.4.7 Emergency preparedness and response (ISO 14001 4.4.7, R2 1.0) 17

4.5 Checking 18

4.5.1 Monitoring and Measurement (ISO 14001 4.5.1, R2 1.0) 18

4.5.2 Evaluation of compliance (ISO 14001 4.5.2, R2 3.0) 18

4.5.3 Nonconformity, corrective action and preventive action (ISO 14001 4.5.3, R2 1.0) 19

4.5.4 Control of records (ISO 14001 4.5.4, R2 13.0) 19

4.5.5 Internal Audit (ISO 14001 4.5.5, R2 1.0) 20

4.6 Management review (ISO 14001 4.6, R2 1.0) 21

5 Revision History 22

1  Introduction

Information Systems Resources (ISR)’s Environmental, Health and Safety Management System (EH&SMS) Manual was developed for reducing ISR’s impacts on the environment and worker health and safety as a result of its operations and activities. This EH&SMS Manual is intended to meet the requirements of ISO 14001:2004 and Responsible Recycling (R2):2008.

ISR operates in a 110.000 square foot facility in Dearborn, MI. ISR is a leading provider of services and products designed to build and manage Computer Network Infrastructures. ISR provides customized, integrated IT solutions. Our services encompass each phase of the computers life cycle process: from design and consulting, procurement and deployment, operation and support, to enhancement and migration.

ISR's customers include fortune 1000 accounts, large healthcare organizations and financial institutions. ISR currently employs over 50 full time personnel with four distinct divisions: Hardware & Software Procurement, Staging, Warehousing & Deployment, and Disposal, Recycling & Remarketing.

2  Reference Documents

Documents referenced in this EH&SMS Manual are as follows:

ISO 14001, Environmental management systems-Requirements with guidance for use; Second edition, 2004-11-15, International Organization for Standardization; Switzerland

Responsible Recycling (“R2”) Practices:2008

3  Definitions

Terms used in this EH&SMS Manual are defined as follows:

Supplier - Persons and organizations that supply goods and/or services that are use in ISR’s recycling operations, and/or the facilities.

Contractor - Persons and organizations that are a subset of suppliers who provide on-site services.

Customer - Persons and organizations that ISR processed material for. Materials may be purchased by ISR or materials may be processed for a fee.

Downstream Vendor - Persons and organizations that provide a service, which consists of processing ISR’s materials. Vendors may charge ISR for processing the material or ISR may be paid for the material.

Visitor - Persons and organizations that visit the site that did not meet any of the above definitions.

4  Environmental, Health and Safety Management System Requirements

4.1  General requirements (ISO 14001 4.1, R2 1.0)

ISR has established, documented, implemented, maintains, continually improves, reviews at least annually and updates as needed a written Environmental, Health and Safety Management System in accordance with the requirements of the ISO 14001 and R2 standards and has determined how it will fulfill these requirements.

ISR’s EH&SMS is based on a “Plan-Do-Check-Act” model for continual improvement.

ISR has defined and documented the scope of its environmental, health and safety management system as follows:

Hardware & Software Procurement, Staging, Warehousing & Deployment, and Disposal, Recycling & Remarketing and de-manufacturing of Computer Network Infrastructures.

Core business processes

ISR has defined a number of core business processes that were designed to efficiently and effectively meet customer expectations while minimizing impacts to the environment and protecting worker health and safety. ISR’s core business is to provide customized, integrated IT solutions. Our services encompass each phase of the computers life cycle process: from design and consulting, procurement and deployment, operation and support, to enhancement and migration and de-manufacturing

ISR has identified its core business processes and their interactions through descriptions in this manual and the Process Flow Diagram.

In order to ensure that these processes are operating effectively, ISR has defined the control mechanisms and monitoring requirements, which are specified in the appropriate procedures or appropriate sections of this manual.

Related and Supporting Documents

4.1-F Process Flow Diagram

4.2  Environmental, Health and Safety Policy (ISO 14001 4.2, R2 1.0)

ISR’s top management has defined ISR’s Environmental, Health and Safety Policy and has ensured that, within the defined scope of its environmental, health and safety management system, it is documented, implemented, maintained, reviewed for continuing suitability, communicated to all persons working for or on behalf of ISR and is available to the public via the ISR website at www.is-resources.com.

Related and Supporting Documents

4.2-P EH&S Policy

4.3  Planning

4.3.1  Environmental aspects (ISO 14001 4.3.1, R2 1.0)

ISR has established, implemented and maintains a procedure to identify the environmental aspects of its activities, products and services within the defined scope of the EH&S management system that it can control and those that it can influence taking into account planned or new developments, or new or modified activities, products and services, and to determine those aspects that have or can have significant impact(s) on the environment.

ISR shall document and keep this information up to date.

ISR shall ensure that the significant environmental aspects are taken into account in establishing, implementing and maintaining its EH&S Management System.

Related and Supporting Documents

4.3.1–P Environmental Aspects Identification Procedure

4.3.1-F Environmental Aspects List

4.3.1-F Significant Aspects Worksheet

4.3.2  Legal and other requirements (ISO 14001 4.3.2, R2 3.0)

ISR has established, implemented and maintains a procedure to identify and have access to the applicable legal requirements and other requirements to which ISR subscribes related to its environmental aspects, health and safety hazards, and other EH&S requirements associated with the commitments they have made.

ISR shall assure that exported equipment and components containing focus materials shall only be made to countries that legally accept such imports.

ISR shall ensure that these applicable legal requirements and other requirements to which ISR subscribes are taken into account in establishing, implementing and maintaining its EH&S management system.

Related and Supporting Documents

4.3.2-P Legal and Other Requirement Identification Procedure

4.3.2-F Legal and Other Requirements Summary List

4.3.3  Objectives, targets and programs (ISO 14001 4.3.3, R2 1.0)

ISR has established, implemented and maintains documented EH&S objectives and targets, at relevant functions and levels within ISR.

ISR’s objectives and targets shall be measurable, where practicable, and consistent with the EH&S policy, including the commitments to prevention of pollution and prevention of injury and ill health, to compliance with applicable legal requirements and with other requirements to which the organization subscribes, and to continual improvement.

When establishing and reviewing its objectives and targets, ISR shall take into account the legal requirements and other requirements, to which ISR subscribes, and its significant environmental aspects and its health and safety hazards. It shall also consider its technological options, its financial, operational and business requirements, and the views of interested parties.

ISR has established, implemented and maintains programs for achieving its objectives and targets documented in Objectives and Targets Program Form. The programs shall include the;

a.  designation of responsibility for achieving objectives and targets at relevant functions and levels, and

b.  means and time-frame by which objectives are to be achieved.

Top Management shall oversee the establishment, implementation and maintenance of the objectives and targets and shall review and update, if necessary the objectives and targets with the associated programs at least twice per year during Management Review meetings.

Related and Supporting documents

4.3.3-F Objectives and Targets Program Form

4.4  Implementation and Operation

4.4.1  Resources, Roles, Responsibility and Authority (ISO 14001 4.4.1, R2 1.0)

Roles, responsibilities and authorities have been defined and documented in this EH&S Management System Manual, the Responsibility Matrix, the Organization Chart, ISR procedures/work instructions and are communicated to those affected individuals.

ISR top management shall ensure the availability of resources essential to establish, implement, maintain and improve the EH&S management system. Resources include human resources and specialized skills, organizational infrastructure, technology and financial resources.

The CEO/President has designated the Chief Operating Officer as the EH&S Management Representative and he/she will assume all roles, responsibilities, and authorities defined throughout the EH&SMS including ensuring that the EH&SMS is established, implemented and maintained in accordance with the requirements of the Standards and reporting to IRS’s top management on the performance of the EH&SMS S for review, including recommendations for improvement.

Related and Supporting Documents

4.4.1-F Responsibility Matrix

4.4.1-F Organization Chart

4.4.2  Competence, Training and Awareness (ISO 14001 4.4.2, R2 1.0)


ISR shall ensure any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental, or health and safety impact(s) is competent on the basis of appropriate education, training or experience, associated records shall be retained.

ISR has established and maintains procedures and training for its employees and vendors associated with significant environmental, health and safety aspects and hazards. Training is conducted taking into consideration different levels of responsibility, ability, language skills, literacy, health and safety risks and required work activities.

ISR has established, implemented and maintains a procedure(s) to make persons working for or on its behalf aware of:

a.  the importance of conformance with the EH&S policy and procedures and with the requirements of the EH&S Management System;

b.  the significant environmental aspects, health and safety hazards/consequences and related actual or potential impacts associated with their work, their behavior and the environmental and health benefits of improved personal performance;

c.  their roles and responsibilities in achieving conformance with the EH&S policy and procedures;

d.  the requirements of the EH&S Management System, including emergency preparedness and response requirements and

e.  the potential consequences of departure from specified operating procedures.

Related and Supporting Documents

4.4.2-P Competence, Training and Awareness Procedure

4.4.2-F Training Needs Matrix

4.4.2-F Visitor and Contractor Sign In Log

4.4.2-F Visitor and Contractor Safety and Environmental Requirements

4.4.3  Communication (ISO 14001 4.4.3, R2 1.0)

With regard to its environmental, health and safety aspects and hazards and the EH&S Management System, ISR has established, implemented and maintains a procedure for;

a.  Internal communication among the various levels of the organization, and

b.  Receiving, documenting, and responding to relevant communication from external interested parties.

ISR made a decision on 2/22/2012 not to communicate its significant environmental aspects to external parties.

Related and Supporting Documents

4.4.3-P Communication Procedure

4.4.3-F External Communication Log

4.4.4  Documentation (ISO 14001 4.4.4, R2 13.0)

The EH&S management system documentation shall consist of this EH&SMS Manual and all associated documentation including;

a.  the EH&S policy, objectives and targets,

b.  description of the scope of the environmental, health and safety management system

c.  description of the main elements of the EH&S management system and their interaction, and reference to related documents,

d.  documents, including records, required by the Standards,

e.  documents, including records, determined by ISR to be necessary to ensure the effective planning, operation and control of processes that relate to significant environmental aspects and heath and safety hazards,

f.  Documentation necessary to show conformity to the Standards shall be maintained onsite.

4.4.5  Control of documents (ISO 14001 4.4.5, R2 13.0)

ISR has established, implemented and maintains a procedure to:

a.  approve documents for adequacy prior to issue,

b.  review and update as necessary and re-approve documents,

c.  ensure that changes and the current revision status of documents are identified,

d.  ensure that relevant versions of applicable documents are available at points of use,

e.  ensure that documents remain legible and readily identifiable,

f.  ensure that documents of external origin determined by organization to be necessary for the planning or operation of the EH&S management system are identified and their distribution controlled, and

g.  prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose.

Related and Supporting Documents

4.4.5-P Document Control Procedure

4.4.5-F Master List of Documents

4.4.5-F Form Revision History

4.4.6  Operational Control (ISO 14001 4.4.6, R2 1.0)

ISR has identified and planned those operations that are associated with identified significant environmental aspects and health and safety risks consistent with its policy, objectives and targets, in order to ensure that they are carried out under specified conditions by:

a.  establishing, implementing and maintaining documented procedures to cover situations where their absence could lead to deviations from the EH&S policy and the objectives and targets;

b.  stipulating operating criteria in the procedures; and