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Online document - Printed copy is "UNCONTROLLED COPY". QUALITY MANUAL Reference No.: BCC-QM3.1 Issue Date: 8 th November 2008 Modified Date: 25 th September 2011 This document describes the Quality Management System of BAHRA CABLES COMPANY Approved for issue: TALAL K. IDRIS Chief Executive officer
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Page 1: BCC-QM3.1 This document describes the Quality … QMS-EM… · BCC-QM3.1 QUALITY MANUAL Date: 25-September-2011 BAHRA Cables Co. Page 4 of 26 Online document - Printed copy is "UNCONTROLLED

Online document - Printed copy is "UNCONTROLLED COPY".

QUALITY MANUAL

Reference No.: BCC-QM3.1

Issue Date: 8th November 2008

Modified Date: 25th September 2011

This document describes the

Quality Management System

of

BAHRA CABLES COMPANY

Approved for issue:

TALAL K. IDRIS

Chief Executive officer

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BCC-QM3.1

QUALITY MANUAL Date: 25-September-2011

BAHRA Cables Co. Page 2 of 26

Online document - Printed copy is "UNCONTROLLED COPY".

Scope

The BAHRA CABLES COMPANY's Quality Management System is designed to plan, to set and implement and to operate within the requirements of BS EN ISO 9001: 2008 without exclusions to this international standard as applicable.

The Quality Manual and associated documentation describes the Quality Management System.

The Issue & Control of the

Quality Manual

The Quality Assurance Manager is responsible for publishing the Quality Manual:

a.) One master copy will be printed and maintained and updated by the Quality Assurance Manager of Bahra Cables Co.

b.) Managers and employees will have access through the Company Intranet

c.) Uncontrolled Copies are made available to potential customers. These copies will not be maintained after their date of issue

THIS QUALITY MANUAL IS CONFIDENTIAL AND THE COPYRIGHT PROPERTY OF BAHRA CABLES CO. IT MUST NOT BE LOANED OR COPIED WITHOUT THE WRITTEN PERMISSION OF BAHRA CABLES COMPANY.

ADDITIONAL COPIES MAY BE OBTAINED FROM THE COMPANY'S QA MANAGER.

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QUALITY MANUAL Date: 25-September-2011

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Table of Contents

Introduction to the Company 4

Policy Statements 5

BCC Organisation Chart 6

Operations Function 7

DOCUMENT PROCEDURE

Interaction of Processes 10

Document Structure 12

Control of Documents 13

Document Planning and Issue 13

Control of Quality Records 15

MANAGEMENT PROCEDURE

Customer Focus 16

Quality Planning 16

Communication 17

Management Review 17

MEASUREMENT PROCEDURE

Measurement, Analysis and Improvement 19

Internal Audits 19

Audit Process 20

Audit Follow up 21

Control of Non-conforming Product 22

Customer Complaints 24

Corrective Action 25

Preventive Action 26

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QUALITY MANUAL Date: 25-September-2011

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Introduction to the Company

Bahra Cables Co. was established in 2008 to serve Saudi & GCC Markets. It is based in Bahra Industrial City located 25km from Jeddah. Bahra Cables factory occupies over 200, 000 square meters of prime manufacturing space together with associated design offices, laboratories and storage area.

It specializes in Manufacturing and Distributing Electric Cables.

Bahra Cables Co. is committed to the production of the best product quality and service, utilizing cutting edge European Technology in its manufacturing.

The organization has a lean vertical management structure which is designed to integrate with a highly developed IT-based structure. This partnership allows the rapid flow of information through the management chain and facilitates timely response in the best traditions of "hands on" management. Bahra Cables Co. has the flexibility to provide a versatile product range to serve the construction, electric utilities, distribution, industrial, oil and gas, and petrochemical sectors.

Product Scope Bahra Cables Co. is committed to deliver the highest standard wires and power cables to the local market and for export. It has a versatile product range to cover most of our customer needs:

Flexible wires and cables up to 300 mm²

Building wires, THHN/THWN to UL83, with conductor sizes starting from16 AWG.

Building wires to IEC 60227 and BS 6004, from 1.5 mm² and above.

LV Power Cables with PVC & XLPE insulation to IEC 60502-1, BS 5476 and UL 1277.

Control and auxiliary cables to IEC 60502 and BS 5476.

Overhead conductors to IEC 889 and EN 80182, ASTM 549.

Cables with low emission of smoke and corrosive gases when affected by fire for LV cables to BS 7211, BS 6724 and BS 7835.

MV/HV cables up to 132 kV to IEC 60840, and to ANSI/ICEA S-108-720, with conductor sizes up to 1000 mm².

Outsourcing Our process model identifies Quality Plans for our production processes. Currently all work is completed in house

Any Processes performed by sub-contractors or sources outside Bahra Cables Co. that affect product conformity are controlled in accordance with the requirements of purchasing process established in this manner

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Policy Statement

BCC’s Quality Policy

Our aim at Bahra Cables Co. is to delight our customers throughout their business association

with us in the supply of electric cables, by achieving:

Total Quality Excellence of product complying with the relevant local and international

standards.

Efficient service and reliability that meets our customer's expectations in every respect.

Continual Improvement of our products and Quality System in order to achieve error

free product.

Enhancing the employee's skills is the main resource of improvements.

Revision of our Business Management System for complying with ISO 9001: 2008.

Proceeding with enhancing the communication and contribution of Management, Employee's,

Suppliers, and Customers, we can provide value superior to that which our customers expect.

TALAL K. IDRISS

Chief Executive Officer

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BCC Organisation Chart

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Operations Function

The Chief Operating Officer reports directly to the Chief Executive Officer.

He is responsible for all the activities carried out by the Operations Group.

A summary of the major tasks Is as follows:

Engineering Technical planning, Plant Design, and Engineering (CAD-Systems)

Planning and forecasting of capital budget requirements and project management in case of investments

General and Planned Maintenance

Statutory Inspections

Installation of plant and equipment

Reporting and correction of manufacturing equipment failures.

Design and construction of production tools and providing technical documents as a base for external supply on demand of and in cooperation with production.

Technology Approval of cable specifications.

Handle the process of the product development and design.

Maintain the International Standards linked to the wire and cables industry.

Provide technical information, products catalogues and solutions for the customers through the sales and marketing department.

Control of the technical elements of customer enquiries and orders and technically review the contracts.

Administration of test and inspection plans for the in-process and finished cables including submission of monthly deviation reports and review of quality problems and solutions.

Issuance and approval of Material Specifications

Approval of calibration agencies and conduct the necessary in-house calibration activities.

Planning Capacity planning in cooperation with Production.

Planning of material demand and disposition and provision of schedules to enable Material Purchase.

Designing of order related product constructions, cost calculations, interface (support) to Sales.

Planning and implementing of production lots (stock orders) from long to short term work scheduling.

Managing stocks of semi finished goods.

Production Capacity planning in cooperation with Planning and putting direct work at disposal for product realization.

Establish optimum process parameters for best quality products and

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methods developed for continual improvement,

Operating the machines efficiently and economically.

Keeping the machines in good order (in cooperation with Engineering Services)

Planning, storage and conditioning of process tooling and supporting devices at disposal.

Statistics on Materials Utilization and initiatives to improve factory performance in terms of materials.

Control of nonconforming product.

In-house training and manpower development.

Warehouse Receipt of incoming raw materials and all purchased items except stationery.

Handling, storage, and managing of raw material stock issues.

The link between Sales and other Departments in the areas of:-

Review of manufacturing capability for customer enquiries and orders.

Provision of bill of material for enquiries.

Confirm the delivery time for the customer quotations and orders.

Handling, storage, preservation and delivery of finished product.

Provision of management control information

Sales and Marketing Prompt attention to customer complaints regarding service.

Processing of customer complaints.

Gaining customer / consultant approvals.

Pricing of offers and final negotiation with customers. Processing of tenders & enquiries

Forecasting of sales. Market research and development of new business.

Promotional activities (exhibits, publications, advertising).

Liaison with Technology Manager regarding customer cable specifications.

Finance Strategic Plan & Budget

Management accounts & forecasts

Financial statements

Risk management

Treasury

Accounts payable / receivables

Human Resources Secretarial service to Board of Directors

Personnel administration

Visas, residency & car licenses

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Social insurance and social scheme

Personnel policies.

Recruitment and staffing.

Identifying resource requirements, including training needs for the department.

Purchasing Provision of new suppliers to approve different sources for each requirement.

Purchase of Raw Materials, spare parts, consumables and services.

Release of materials and spare parts, etc. from Customs (Imported).

Perform the purchase agreements for efficient purchasing terms and conditions.

Quality Assurance Quality Assurance Manager is appointed as Management Representative.

He is responsible for ensuring that the Quality Management Systems is established, implemented and maintained in accordance with the Company Policy,

Reporting on the performance of the Management Systems to the management review as a basis for continual improvement.

He has the organizational freedom to resolve all matters pertaining to quality „Management Systems' Manuals preparation and approval.

Preparation of all systems' procedures.

Distribution and control of all management systems' documentation.

Liaison with management systems' external assessor.

Monitoring the implementation and effectiveness of the Management Systems.

Initiates Internal Audits and Management Reviews.

Handling of material and customer complaints.

Review of nonconformities and solutions to report for the management review for corrective and preventive action.

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DOCUMENT PROCEDURE

Interaction of Processes

SalesQuotation request

Issued by planning

Production Orders (PO) for each process

PO issued for all processes with scheduled date based

upon line speeds

Production

Machine set up from Design Sheet

Checks undertaken in accordance with Quality plan for

product family

Quality Control

On line checks undertaken following schedule

Recorded on line quality sheet

Calibration

Detailed records of calibration

Production plan

Materials available issued by logistics

Machinery available planned maintenance schedules agreed

Manpower availableHR have provided all

manpower identified

on Organisation Chart

Final release after testing

Warehousing

Delivery to client

Resource Management

Organisation chart with personnel

requirements

Planned maintenance systems in

operation

Customer satisfaction review by sales

Confirmation plan for production achieved

Review QC and production test results

Review downtime on each machine

Corrective action reports

Preventive action reports

Management

Appointment M R

Awareness.

Management Review

Customer Quotation

Planning.

Confirm dates for order requirementConfirmed acceptance and

delivery schedule to customer

Technology

Production of Design Sheet from product family master

New Product Family

Design process following agreed procedureDesign sheet

Yes

No

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Quality Policy

Quality Manual

This will include all procedures for managing the quality programme

Quality Plans

including Work Instructions.

Quality plans will be prepared for Machine Shop Operation, Welding Operations and

Finsihing and Testing requirements

Forms

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Document Structure

Quality Policy This policy contains a statement from the Managing Director. It will be signed and prominently displayed at all locations

All Managers and supervisors must ensure that their employees are trained on their roles and responsibilities in the Quality System and its proper maintenance.

Quality Manual This document is issued by the Managing Director, and is the interpretation of the requirements of ISO 9001:2008

It contains policies that outline the Company‟s Quality philosophy. The policies are linked to measurable goals, which are monitored on a frequent basis.

Quality Operating Procedures

Quality Procedures are produced for each of the departmental processes

The controls applied throughout the process

Associated process and product specifications

In process and final checks before product release

Work Instructions These will only be produced to direct particular tasks and activities where their absence could affect Quality.

The Supervisors responsible for the activity concerned will produce these.

Quality Library A Quality library will be established under the control of the Quality Assurance Manager. The library will contain a copy of the Quality Manual; a Master Copy of the current and archived Quality procedures, Work Instructions and forms.

It will be the responsibility of the Quality Assurance Manager to ensure that the current copies are available.

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Control of Documents

Control of Documents

All internal Quality System Documents shall contain the document number, title and revision level. All Quality System Documents will be reviewed and approved for adequacy prior to issue by authorized personnel. Evidence of approval will be identified on the document concerned.

All Internal Quality System Documents shall be formally reviewed and updated periodically or at least annually as necessary to comply with the latest revisions of the API Specifications and other International Standards. This will be undertaken to re-affirm the adequacy of the Quality System to current Company requirements.

It is the responsibility of the Quality Assurance Manager to review the Company Quality Management System to ensure that invalid and/or obsolete documents are promptly removed from all points of issue or use, or otherwise assured against unintended use.

Document Planning and Issue

Step Description

Internal Quality System Documents

MUST:

Contain the document number and title

Issue date and Issue number

Record revision status

Be reviewed and approved prior to issue by authorized personnel. Evidence of approval will be identified on the document concerned

Be reviewed and approved for changes by the same issuing authority, prior to re-issue.

Be identified as controlled by the colored title on the heading and in accordance with the Distribution Register. All documents not identified in this manner will be considered as Uncontrolled.

Ensure that all changed or superseded documents are withdrawn from the system and destroyed .An archived copy will be retained by the Quality Assurance Manager.

Document Changes:

Any person in the organization may submit a Change Note

Where changes are required through non-conformances or audit failures, the non-conformance report is sufficient to generate a change.

All proposed changes will be circulated by the Quality Assurance Manager to all affected personnel for review prior to change implementation.

Change will be handled through the Quality Assurance Manager. He will review the document. Where he considers the document acceptable as part of the continuing improvement philosophy, he will prepare a draft change for approval by:

1 the Executive Chairman where a change is made to the Quality manual

2 the Workshop Manager where it affects Department Quality

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Plans

Once the final draft is approved, the Procedure will be re issued as the next issue number. Changes will be identified on the Document Change History.

The Quality Assurance Manager will remove the obsolete document from the Master File and place this in the obsolete policies folder.

For all Quality Plans, the Managers will issue.

All changes to the Quality Documents shall be identified by a new revision number. If required however, the change will be made using a New Issue of the Document.

Temporary Handed Changes on i.e. Production Order specification should be controlled or sign by the responsible person.

All Quality System Documentation shall be stored correctly to prevent deterioration and such documents shall be clearly legible and readily available at the point if use

External Documentation and Data

A list of the externally supplied specifications, procedures and drawings within the company shall be controlled and maintained by the Quality Assurance Manager. This covers all International, National Standards and specifications required

This list shall contain the following minimum information

a) Number and Title of Specification or Standard.

b) Revision number and/or date.

c) Company Designation.

d) Registered holder or location.

The Quality Assurance Manager will maintain a record of all such documents held.

A Distribution shall be maintained defining where such documents are held.

An annual review shall be made to confirm the current validity of the standards. The date of this evaluation must be recorded.

All new and amended standards will be obtained and issued to the defined holders of the document.

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Control of Quality Records

Step Description

Identification of Quality Records

Records shall be identifiable. As part of its identification, records shall contain but not limited to the following:

A title, reference/control number, date of record, name/signature of the person who prepared the record, corresponding approval where applicable.

Archival documents and data retained for legal or knowledge preservation purposes or both are suitably identified.

Protection, Storage, Retrieval of Quality Records

Quality records shall be kept in a place where it can be protected from physical deterioration and damage. It shall also be kept in a safe place to avoid loss and tampering. Quality records shall also be labeled

properly for ease of retrieval and for proper referencing.

Retention of Quality Records

Records shall be retained a minimum period of five years and the records required by API product specifications shall be retained for the period of time specified therein. The retention period of all Quality records shall be the discretion of each department. Each department shall define for how long they shall keep their quality records in their custody complying with legal and statutory requirements.

Disposal of Records

At any time after this period, subject to management review and approval, and unless specifically requested otherwise by the client, the Quality Assurance Manager shall ensure that such documentation is disposed of in accordance with BCC‟s requirements

Control of Records

Quality records shall be prepared as evidence of compliance with the contents of the Quality Manual and or procedures and contractual agreements. All such documents shall be clearly legible and provide traceability to the items which they relate.

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MANAGEMENT PROCEDURE

Management Commitment

Establishing and Approving the Company Quality Policy and ensuring

that this policy is understood and maintained by all Company

personnel.

Communicating to the organization his commitment to the development

and improvement of the Quality System.

Undertaking Management Reviews of the Quality System and its

component parts.

Reviewing commitments at Quality Management Review Meetings.

Establishing and Approving Company Objectives. These objectives will

be prepared for all departments within the Company where the

outcomes of their activities affect Quality.

Ensuring that there are enough resources available to implement and

maintain the Company Quality Management System. The processes

for the above will be covered throughout the Company Quality

Management Systems and throughout the organization.

This will be done by a number of factors such as Management Review

Meetings (Twice as a minimum), six monthly internal audits and at

least yearly external audits. The departmental objectives will be

reviewed and the results will be discussed at the Management Review

Meetings.

Holding Management and Inter-departmental meetings to ensure that

communication is developed between the departments to aid the

implementation and maintenance of the quality system.

Customer Focus

The Chief Executive Officer is responsible for ensuring that customer requirements are determined and are met.

We will measure customer satisfaction to ensure commitment.

Quality Planning

Quality Planning Quality Planning will give consideration to the following activities, as appropriate, in meeting specified requirements.

The identification and acquisition of any controls processes, equipment (including inspection and test equipment). Resources and skills that may be needed to achieve the required quality.

Ensuring the compatibility of the design, the production process, inspection and test procedures and applicable documentation.

Installation and Servicing, if required by the client.

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The updating, as necessary of quality control inspection and testing techniques including the development of new procedures and instrumentation.

The identification of suitable verification of parts in process.

The clarification of standards of acceptability.

The identification and preparation of quality records

Quality Audits

The planning of new designs or modification of existing design shall be conducted.

Quality Objectives Quality Objectives will be prepared, in consultation with the Department Person, and approved by the Department Manager. These objectives will be documented and issued to the Departmental Managers individually and will be measured and analyzed periodically to show the continuous improvement of the Company. These objectives will meet the requirements of the product / service provided and will be consistent with the Quality Policy.

Quality Management System Planning

Top Management shall ensure that;

The planning of the Quality Management System is carried out in order to meet the requirements, as well as the Quality Objectives.

The integrity of the Quality Management System is maintained when changes to the Quality Management System are planned and implemented.

Communication

Internal Communication

Management shall ensure that appropriate communication processes are established within the organization and that communication takes place regarding the effectiveness of the quality management system.

Management Review

Procedure The Management Review Meeting of the Quality System shall be conducted annually as a minimum of twice per year.

The Quality Assurance Manager shall inform the attendees of the review meeting. Attendees will be

Chief Executive Officer

Chief Operating Officer

Engineering Manager

Technology Manager

Production Manager

Warehouse Manager

Sales Manager

Finance manager

Human Resource Manager

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Procurement Purchasing Manager

The Management shall review the Quality Management System to ensure its‟ continuing suitability, adequacy and effectiveness in satisfying the requirements of International Standards

Meeting Agenda Customer Feedback

Internal and External Quality audit results-where applicable

Process performance

Product Conformity-(Non-conformances-Analysis of trends)

Corrective and Preventive action All non-conformances shall be evaluated and the corrective action assessed for effective implementation.

Vendor performance

Changes to Standards-National and International Standards, Product Standards.

Changes that could affect the Quality Management System-Any changes shall be reviewed, also any changes in work practices.

Performance against defined company objectives.

Recommendations for Improvements.

Any other business.

Meeting Report The Quality System Review shall be fully recorded, signed and distributed to the relevant parties and will include where applicable, corrective action is required and time frame for implementation.

The Quality Assurance Manager shall produce a meeting report which will include:

Corrective and Preventive Action

Internal Quality Audit

Customer Complaint

Agreed Action Plan for continuous improvement. All actions/changes which have not been cleared from the previous meeting shall be discussed and brought forward and reviewed at the next meeting

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MEASUREMENT PROCEDURE

Measurement, Analysis and Improvement

General Bahra Cables has implemented a monitoring, measurement, analysis and improvement process which:

Demonstrates conformity of the product,

Ensures conformity of the quality management system

Continually improves the effectiveness of the quality management system.

Customer Satisfaction

BAHRA CABLES has established parameters to be used to measure customer satisfaction relating to customer perception as to whether the organization has met customer requirements.

BAHRA CABLES has established an analytical program for all factors affecting customer satisfaction. Quarterly reports will be issued to all Managers in the Company concerning issues that are affecting customer satisfaction.

BAHRA CABLES ensures that reports of customer satisfactions are available for discussion at the Management Review Meetings.

It is the responsibility of the Departmental Managers to ensure that measures of customer satisfaction are communicated to all supervisors and employees under their control.

Areas to be Analyzed for Customer Satisfaction

Feedback on all aspects of Product and Service

Customer needs & Contract Obligation

Service delivery data, including quotations, delivery times etc.

Customer Perception of Company.

Levels of professionalism within the Company.

Internal Audits

Internal Audits BAHRA CABLES carries out a program of comprehensive internal audits to verify that quality, health and safety activities comply with the management system and also with relevant standards.

Internal audits of areas involved in the management system are programmed at intervals of not more than 12 months by the Management Representative, in accordance with BAHRA CABLES procedures, and are carried out by trained auditors.

Auditors shall be independent of the areas being audited and results of audits shall be brought to the attention of personnel having responsibility for the work area or project. All items arising from the audits are reviewed and followed up to verify effective corrective and preventive action.

Audit Records All records of Internal Quality Audits and their results shall be maintained for a period of five (5) years

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Audit Process

Step Description

Audit Planning The program for the audit plan is computer generated. It identifies the areas to be audited and the month for the audit. The Management Representative will take into account the weight needed for the assessment based upon company needs. The audit schedule will be approved by the Management Review Committee.

Preparing for the Audit

Auditors will receive a copy of the annual program. This will identify the month for each audit. They will contact the auditee and arrange for a mutually convenient date for the audit.

Auditors will obtain from the management representative copies of the outstanding NCR‟s. The plan for the audit must ensure that these non-conformances are the first item on the audit.

Auditors will use pre prepared audit checklists and must plan the audit to ensure that they have at least one hour to review the audit performance and 30 minutes for preparation of any NCR‟s and the audit report

Audit Conduct Auditors will carry out the audit on the day agreed. They will identify on the checklist the objective evidence that they have reviewed and where they have discrepancies. Once they have completed the audit they will review the information and produce any non-conformances in accordance with the definitions in this procedure.

This information will be contained on the checklist with a note of the action taken to avoid recurrence of the problem.

Audit Reporting Present Audit findings to Auditee at closing meeting, agree required corrective actions, timescales and responsibilities with the auditee, obtain signature of auditee indicating acceptance of non-conformances reported.

The original report is retained by the auditee. A copy is returned to the Management Representative together with the original checklist.

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Audit Follow Up

Step Description

Audit Review All non-conformances and audit results will be identified on the computer generated record system.

Management Representative will receive the report from the auditor

He will initially review this report and discuss with the auditor any reasons for concern.

Once satisfied with the report he will sign off acceptance

He will mark all non-conformances on the log on the system and identify on the program the number of non-conformances.

Follow up Internal Audits

Where a major non-conformance has been reported a follow up audit will be undertaken no later than 7 days after the agreed date for corrective action.

All other follow ups will be undertaken at the next scheduled audit.

The Management Representative must ensure that copies of the non-conformances are with the auditor before the audit.

Management Reviews

Internal Audits

The Management Representative will collate the results for review on the audit summary. This will be reviewed at the Management Review Meeting. Actions from this will be contained in the minutes of meeting.

Audit Review On an annual review the Management Representative will review the audit results and will consider whether to update the Internal Audit Plan to reflect the results of the audits obtained.

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Control of Non-conforming Product

General Controls provide for the identification, documentation, evaluation and segregation and disposition of non-conforming product and for notification to the functions concerned.

Our controls will ensure that non-conforming product is identified and controlled to prevent its unintended use or delivery

Where required by contract, the proposed use or repair of product which does not conform to specified requirements shall be reported to the customer for concession. The description of non -conformity that has been accepted, and of repairs, shall be recorded to denote the actual condition.

Where non-conforming product is detected after delivery, we shall evaluate the effects and potential effects with the customer

This process apply to finish product only.

Criteria for Evaluation, release and acceptance of non conforming product

The process of evaluation and disposition of non-conformance shall include one or more of the following:

Accepting materials or products that do not satisfy manufacturing acceptance criteria provided.

Materials or products satisfy the design acceptance criteria.

The violated manufacturing acceptance criteria are categorized as unnecessary to satisfy the design acceptance criteria.

The materials or products are reworked to satisfy the design acceptance criteria or manufacturing acceptance criteria.

Responsibilities The COO shall establish controls, which identify disposition and analyses data from any non-conforming materials or processes.

The Department Manager and Quality Assurance Manager are jointly responsible for handling non- conforming product and with the Workshop Manager having the authority to utilize all resources for the disposition of non- conforming products and materials Supervisors and Operators will identify and report any non-conforming product or materials encountered during process operation

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Step Description

Rejection of material or process

When material or a process is rejected at any stage, the inspecting personnel concerned shall raise a Non-Conformance Report or fault card.

The non-conforming product shall be placed in the Quarantine Area and a non-conformance tag shall be filled out and attached

The description of non-conformity that has been accepted, and of repairs, shall be recorded to denote the actual condition.

Non-conformance Report

The inspection personnel shall complete the Non-Conformance Report or fault card.

Each Non-Conformance Report or fault card shall be given a unique number. The next sequential number shall be utilized which is taken from the Non-Conformance Log

All concerned functions shall be notified of the non-conformance and disposition.

Evaluation The Departmental Manager and Quality Assurance Manager will review the product and decide upon the action to be taken based upon the defined criteria. They will report their findings on the Product non-conformance report. They will either consider

1. Application for a concession. Records of the concession will be recorded and attached to the Product non-conformance form

2. Release as defined in criteria evaluation where the product meets either design criteria or manufacturing criteria is unnecessary to satisfy design acceptance criteria

3. Rework or repair

4. Scrap the product

Re work Where the product is reworked, it will be given a new Works number with the suffix R. This will enable the cost of rework to be established as part of the continuous improvement program.

Re work will follow defined manufacturing processes and will be released only after satisfying all defined quality parameters during re-verification

Corrective Action Corrective Action shall be performed in accordance with the “Corrective Action” procedure. The CA shall be entered on the NCR Report and Log for traceability and cross-reference.

Completion

The non-conforming material or products shall not be processed or reworked until the disposition and evaluation has been performed, approved and release documented.

Records shall be maintained for a minimum of 5 years

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Customer Complaints

Step Description

Contract Dept All customer complaints are received by the Sales and Marketing Department. They are recorded in customer complaints log by the Management Representative. The Sales and Marketing Manager will contact the customer to review whether the complaint is justified. If, in his opinion it is, he will contact or arrange for samples of the product to be returned for examination.

Depending upon the problem, this may require a visit by the Sales and Marketing Manager and the appropriate specialist within the organisation.

Accepted

If he does not think the complaint is justified, he will make a recommendation for the Management Representative to action and to update the Customer

NCR Raised The complaint is sent to the Management Representative. He will raise a Non Conformance Report (NCR) and forward this to the manager responsible for the product or service that is the cause of the complaint.

Product Returned If goods are returned, they should be placed in quarantine area, marked hold with the customer complaint reference number attached

Investigation The Department Manager will investigate the cause of the problem, looking initially at the immediate corrective action that is to be taken.

Sales and Marketing

The Sales and Marketing Manager will respond to the customer

Management Review

The Management Representative will arrange for each customer complaint to be reviewed at the next planned audit to ensure that the corrective action has been effective. He will report the result of the finding to the subsequent Management Review

No

YES

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Corrective Action

Scope and Purpose To ensure that effectice corrective action is carried out and maintained regarding conditions adverse to Quality and prevention of non-conformance recurrence

Applicable to all functions including manufacturing, inspection, testing, customer complaints, audits (internal and external) and suppliers actively used by BAHRA CABLES where corrective action is deemed necessary

Corrective action may be required as a result of non-conformances arising from:

Non-Conformance trends

Supplier materials or service

In-process functions

Customer complaints

Audits (internal & external)

Inspection

Management Quality System Review

All corrective actions shall be addressed within 30 days of the Corrective Action being raised. If the length of the time required is longer than a disposition can be granted but this shall require the approval of the Quality Assurance Manager and the Chief Executive before acceptance of the timescale

Step Description

Corrective Action

Quality Assurance Manager informed of all non-conformances

Quality Assurance Manager completes the Non-conformance Report, Audit Report Number or applicable document and process involved.

Non-conformance Report forwarded to relevant Manager

Manager will review the problem and

a. Identify the root causes of the problem.

b. He will review the root cause and identify a solution to ensure that the problem cannot recur

c. Quality Assurance Manager and relevant Manager will agree suitable corrective sign the NCR including an agreed date for implementation and completion.

Corrective Actions to be completed, updated and followed up

Summary of Corrective Action‟s will be reviewed at the Management Review Meeting

Corrective action that cannot be agreed shall be forwarded to the Executive Chairman to resolve.

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Preventive Action

Preventive Action Preventive actions are appropriate to the effects of the potential problem. Preventive action procedure includes:

a) The use of appropriate sources of information such as processes and work Workshop which affect product quality, concessions, audit results, management review, quality records, and customer complaints to detect, analyses and eliminate the potential cause of nonconformity.

b) Determination of the steps needed to deal with any problems requiring preventive action

c) Initiation of preventive action and application of controls to ensure that it is effective.

d) Ensuring that relevant information on action taken is submitted to Management for review.

It is the responsibility of all personnel to continually monitor their work environment and requirements and to highlight to their Supervisor, QC or Quality Assurance Manager any area of function in which a potential improvement or change may be necessary.

Any potential preventive action will be submitted in writing to the responsible manager for concurrence/comment.

After implementation the area will be monitored for a time period deemed suitable to ensure that the action is acceptable and implemented.

Records All records relating to this procedure shall be retained for a minimum period of 5 years.

Step Description

Corrective Action

Quality Assurance Manager informed of all non-conformances

Quality Assurance Manager completes the Non-conformance Report, Audit Report Number or applicable document and process involved.

Non-conformance Report forwarded to relevant Manager

Manager will review the problem and

a. Identify the root causes of the problem.

b. He will review the root cause and identify a solution to ensure that the problem cannot recur

c. Quality Assurance Manager and relevant Manager will agree suitable corrective sign the NCR including an agreed date for implementation and completion.

Corrective Actions to be completed, updated and followed up

Summary of Corrective Action‟s will be reviewed at the Management Review Meeting

Corrective action that cannot be agreed shall be forwarded to the Executive Chairman to resolve.

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Reference No.: BCC-EH1Dated: 17th April 2010

This document describes the

Integrated Environmental and Occupational Health and Safety System

of

BAHRA Cables COMPANY

Factory/Sales Office Address at:CPC Industrial Park

Makkah Hi-way RoadP.O Box 11967,

Jeddah 21463 KSATel : +966 2 591 1115Fax : +966 2 591 5683

Approved for issue :

TALAL K. IDRISSChief Executive Officer

Environmental, Occupational Health and Safety Manual

QUALITYMANUAL

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Ⅰ. Manual Approval

Document Name : Environmental and Occupational Health and Safety ManualVersion : 0Issue date : 17/ 4 / 2010

This is a controlled document and not to be copied without authorization from Bahra Cables Company. Only originals, signed by Environmental and Health and Safety Manager, may be used as working documents.

QUALITYMANUAL

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Ⅱ. Table of Contents

QUALITYMANUAL

Page Subject 14001 18001

2 Manual Approval X X

3 Table of Contents X X

4 Introduction X X

4 Enviromental and Occupational Health and Safety 1 1

4 Scope and Normative Reference 2 2

4 Definitions 3 3

6 EMS & OHSAS Requirements 4 4

6 General Requirements 4.1 4.1

7 EMS & OHSAS Policy 4.2 4.2

8 Planning 4.3 4.3

6 - Environmental Aspects 4.3.1 ------

8 - Hazard Identification, Risk Assessment and Determining Control

------ 4.3.1

9 - Legal and other Requirements 4.3.2 4.3.2

9 - Objectives, Targets and Programmes 4.3.3 4.3.3

10 Implementation and Operation 4.4 4.4

10 - Resources, Roles, Responsibility, Accountability and Authority

4.4.1 4.4.1

10 - Competence, Training and Awareness 4.4.2 4.4.2

11 - Communication, Participation and Consultation 4.4.3 4.4.3

11 - Documentation 4.4.4 4.4.4

12 - Control of Document 4.4.5 4.4.5

12 - Operational Control 4.4.6 4.4.6

13 - Emergency Preparedness and Response 4.4.7 4.4.7

14 Checking 4.5 4.5

14 - Monitoring and Measurement for EMS 4.5.1 ------

14 - Performance Measurements and Monitoring for OHSAS ------ 4.5.1

14 - Evaluation of Compliance 4.5.2 4.5.2

14 - Incident Investigation, Nonconformity, Corrective and Preventive Actions

4.5.3 4.5.3

15 - Control of Records 4.5.4 4.5.4

16 - Internal Audit 4.5.5 4.5.5

17 Management Review 4.6 4.6

19 List of Documented Procedures X X

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Ⅲ. Introduction

Bahra Cables Company is implementing its EMS AND OHSAS, which comply with the international standards 14001:2004, and OHSAS 18001: 2007 The purpose of this Manual is to guide and instruct all employee whose actions can interact with the products, environmental and occupational health and safety performance, as well as to inform the public about company applied controls to show effective implementation of the systems and its continual improvement.

IV. Environmental and Occupational Health and Safety

1.0 Scope

Bahra Cables Co. is committed to deliver the highest standard wires and power cables to the local market and for export. It has a versatile product range to cover most of customer needs:a. Flexible wires and cables up to 300 mm2.b. Building wires, THHN/THWN to UL83, with conductor sizes starting from16 AWG.c. Building wires to IEC 60227 and BS 6004, from 1.5 mm2 and above.d. LV Power Cables with PVC & XLPE insulation to IEC 60502-1, BS 5476 & UL 1277e. Control and auxiliary cables to IEC 60502 and BS 5476.f. Over head conductors to IEC 889 and EN 80182 , ASTM 549g. Cables with low emission of smoke and corrosive gases when affected by fire, for LV cables to BS 7211, BS 6724 and BS 7835.h. MV/HV cables up to 132 kV to IEC 60840, and to ANSI / ICEA S-108-720, with conductor sizes up to 1000 mm2.

2.0 Normative Reference

There are no normative references in the Standards EMS & OHSAS.

3.0 Definitions

3.1 Environmental Definitions

3.1.1 Continual ImprovementProcess of enhancing the environmental management system to achieve improvements in overall environmental performance in line with the organization’s environmental policy.

3.1.2 EnvironmentSurroundings in which an organization operates, including air, water, land natural resources, flora, fauna, humans, and their interrelation.

QUALITYMANUAL

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3.1.3 Environmental AspectElement of an organization’ activities, products, and services that can interact with the environment.

3.1.4 Environmental ImpactAny change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products and services.

3.1.5 Environmental ObjectiveOverall environmental goal, arising from the environmental policy; that an organization sets itself to achieve, and which is quantified where practicable.

3.1.6 Environmental TargetDetailed performance requirement, quantified where practicable to the organization, applicable to the organization parts thereof that arises from the environmental objectives and the needs to be set and met in order to achieve those objectives.

3.1.7 Environmental PerformanceMeasurable results of the environmental management system, related to an organization’s control of its environmental aspects, based on its environmental policy, objectives and targets.

3.2 Occupational Health and Safety Definitions

3.2.1 HazardSource or situation with a potential for harm in terms of injury or ill health, damage to property, damage to the workplace environment, or a combination of these.

3.2.2 Hazard identificationProcess of recognizing that a hazard exists and defining its characteristics.

3.2.3 Incident:Event that gave rise to an accident or had the potential to lead to an accident.

3.2.4 AccidentUndesired event giving rise to death, ill health, injury, damage or other loss.

3.2.5 RiskCombination of the likehood and consequence (s) of a specified hazardous event occuring.

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3.2.6 Risk AssessmentOverall process of estimating the magnitude of risk and deciding whether or not the risk is tolerable.

3.2.7 Tolerable RiskRisk that has been reduced to a level that can be endured by the company having regard to its legal obligations and its own policy.

4.0 EMS & OHSAS Requirements

4.1 General Requirements

a. Establishes, and maintains EMS & OHSAS that satisfies ISO 14001:2004, and 0HSAS: 18001:2007. b. Identifying the process for EMS & OHSAS and the applications.

c. This manual describes the organizational responsibilities and procedures used in the control of environmental aspects and hazards of activities associated with significant impacts or risks.

d. Monitoring, measures and analyzes the processes.

e. Bahra Cables Company implements actions necessary to achieve planned and continual improvement of the processes.

f. It is the responsibility of all employees to assist in implementing the procedures and the work instructions effectively.

g. Department Managers are responsible to demonstrate improvement of EMS & OHSAS performance and to ensure that the requirements are effectively implemented and comply with Saudi Arabia laws and regulations.

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QUALITYMANUAL

4.2 Environmental And Occupational Health And Safety PolicyProcedure : Objectives and Programs (QAP-EH-010

Bahra Cables Company is committed to supply its customers with quality cables using environmentally preferable equipment and raw materials and ensuring that its products have stable characteristics and are manufactured according to the relevant international standards.

Moreover, Bahra Cables Co. is committed to:

• Implementing a health & safety environmental management system that is continually improved over time to ensure pollution prevention.

• Pollution prevention, waste minimization, and the wise use of materials and energy.

• Controlling its occupational health and safety risks and evaluating its impacts to eliminate or minimize the risks associated with it.

• Providing a safe and healthy work environment for its employees, neighboring facilities and community and safeguard products, tools and company facility.

• Complying with all relevant statutory legislation and BCC’s General corporate HSE requirements.

• Where cost effective, reuse, recycle or resell materials scrapped in the manufacturing process.

• Pursuing the goal of no harm to employees and neighbours.

• Periodically review and update this policy

This policy is available to the public upon request.

TALAL K. IDRISSChief Executive Officer

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4.3 Planning

4.3.1a Environmental Aspects

EMS : Clause No. 4.3.1Procedure : Environmental Aspects and Impacts (QAP-EH-002)

Department Managers whose activities are expected to have an environmental influence are responsible for :

• Identify environmental aspects of their departmental activities in order to determine those have or can have significant impacts on the environment.

• Identify and evaluate the environmental impacts of their activities. • Subject any new activities for evaluation in order to determine their associated significant environmental aspects and impacts. • Ensure that significant impacts of departmental activities are considered in setting environmental objectives.

• Update records of environmental aspects and impacts.

4.3.1b Hazard Identification, Risk Assessment and Determining Controls

OHSAS : Clause No. 4.3.1Procedure : Hazard Identification and Risk Assessment ( QAP-EH-001)

Department Managers are responsible to identify the hazards and carry out risk assessment of their departmental activities including :

• Routine and non-routine activities. • Activities of all personnel having access to their work place. • Facilities at their work place.

Every Department Manager is responsible to decide whether the existing or planned controls are adequate, and hence implementation of necessary control measures to reduce hazard.

Results of risk assessment are considered when setting OH & S objectives.Every Department Manager is responsible to update the records of hazard identification, risk assessment and risk controls.

The methodology of hazard identification and risk assessment is carried out according to assessment and risk control “ Hazard Identification and Risk Control” documented procedure.

OH & S Committee is responsible for reviewing hazard identification and risk assessment records to ensure that the provided controls are adequate to reduce.

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4.3.2 Legal and Other Requirements

EMS : Clause No. 4.3.2OHSAS : Clause No. 4.3.2Procedure : Legal and Other Requirements (QAP-EH-005)

Management Representative is responsible to identify and have access to legal and other requirements to which Bahra Cables Company subscribes that are appreciable to the environmental aspects as well as the occupational health and safety requirements that are associated with the activities and products.

All departments whose activities have or can have environmental aspects or Hazards are informed with the applicable legal and other requirements.

Control of legal and other requirements will be conducted according to procedure “Control of Documents”.

4.3.3 Objectives, Targets and Programs

EMS : Clause No. 4.3.3OHSAS : Clause No. 4.3.3Procedure : Objectives and Programs (QAP-EH-010)

Bahra Cables Company’s top management is responsible for determining specifically the company’s objectives and targets for both EMS and OHSAS.

Management Representative is the coordinator between the top management and the departments to define the objectives and to facilitate and save the required resources.

All objectives are measurable and consistent with the EMS and OHSAS policy.

Objectives and targets are established, maintained and documented by considering the followings:a. Aspects related to the significant impacts and hazards.b. Applicable legal and other requirements.c. Company applicable technology.d. Business requirements.e. View of interested parties.

Each department is responsible for identifying, and planning its objectives and targets for achieving them to ensure the continuous development in the department.

Bahra Cables Company provides adequate different resources, including those needed to meet requirements for company products at relevant levels.

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QUALITYMANUAL

Planned resources by different authorities are scheduled and made timely available for all verification activities.These resources include:a. Trained personnel.b. Appropriate equipment.

The adequacy of resources for the suggested objectives and target is reviewed in the course of the regular management reviews.

Management Representative and concerned Department Managers are responsible to establish, maintain and update documented programs for achieving objectives and targets which may include:a. Designation of responsibilities.b. Means, resources and time frame.c. Amendment according to changes in activities and or information.

Objectives and programs are periodically reviewed by top management in management review meetings.

4.4 Implementation and Operation

4.4.1 Resources, Roles, Responsibility ,Accountability and Authority

EMS : Clause No. 4.4.1OHSAS : Clause No. 4.4.1

The organization charts of Bahra Cables Company presented in Appendix [A], shows the personnel having direct responsibility for the control, maintenance and continual improvement of EMS and OHSAS .

Job descriptions are issued and distributed in order to define roles, responsibilities and authorities in order to facilitate effective implementation of EMS and OHSAS.

Resources essential to implement and control EMS and OHSAS including human resources, training and financial resources have been provided by top management.

Management Representative is responsible for: • Ensure establishment, implementation and maintenance of environmental management system in accordance to EMS and OHSAS . • Report on the performance of environmental management system and its continual improvement.

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QUALITYMANUAL

4.4.2 Competence, Training and Awareness

EMS : Clause No. 4.4.2OHSAS : Clause No. 4.4.2Procedure : Training (QSP-HR-001)

Bahra Cables Company’s management are responsible for identifying the training needs for all personnel whose work may create a significant impact upon the environment and the required competence to control hazard in order to ensure that they have received appropriate training.Employees at each level and relevant function are aware of: • The importance of conformance with EMS and OHSAS policy and procedures. • Their responsibilities in achieving conformance with the requirements of emergency preparedness and response. • The significant environmental impacts and the associated hazard of their work, activities and the benefits when improving their performance. • The potential consequences of departure from specified operating procedures. • Personnel performing tasks that can have significant environmental impacts or associated with hazard are competent on the basis of appropriate education, training and/or experience according to the basis of work instruction used. • Training activities are performed according to training procedure and the training records are maintained according to control of records procedure.

4.4.3 Communication, Participation and Consultation

EMS : Clause No. 4.4.3OHSAS : Clause No. 4.4.3Procedure : Communication, Participation and Consultation (QAP-EH-006)

Internal communication between various levels and functions are defined through job descriptions.

Relevant information and requests from interested parties are received, documented and delivered to relevant manager to ensure effective and open communication of environmental, healthy and safety information.

Bahra Cables Company established documented procedure for communicating the EMS and OHSAS policy, objectives and targets to the various levels and functions through appropriate ways to ensure employee involvement and consultation.

External communications with interested parties and public authorities are defined and documented.

Bahra Cables Company established documented procedure to receive and resolve the environmental complaints.

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4.4.4 Documentation :

EMS : Clause No. 4.4.4OHSAS : Clause No. 4.4.4

Bahra Cables Company establishes documentation for both EMS and OHSAS, in a paper form or electronic form to ensure the effectiveness and efficiency and it is consists of : • EMS and OHSAS policy and objectives. • EMS and OHSAS manual. • Documented procedures and work instructions. • Adequate forms needed to ensure the effective planning, operation and control of all Bahra Cables Company ’s activities. • EMS and OHSAS records. • Legal and other requirements

4.4.5 Control of Documents

EMS : Clause No. 4.4.5OHSAS : Clause No. 4.4.5Procedure : General Document and Data Control (QSP-QMS-001)

Documents are prepared, reviewed and approved for adequacy by authorized personnel prior their issuance, changing and / or modifications.

Documents are controlled through its Document Control No. and revision number as well as issue/ revision dates.

QA department is responsible for controlling, issuing, distribution of documents at locations where they are intended to be used.

A master list defying the current status of documents is readily available in QA department, to preclude the use of invalid and / or obsolete documents.

Obsolete and / or invalid documents are promptly removed from locations of issue or use and are destroyed or currently identified, especially for documents retained for legal and / or knowledge preservation, to avoid their unintended use.

All changed and modifications of environmental manual are carried out according to “Document Issuance and Control instruction”.

Documents are prepared in accordance with “General Document and Data Control” Procedure and “Document Issuance and Control” Work Instruction.

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4.4.6 Operational Control

EMS : Clause No. 4.4.6OHSAS : Clause No. 4.4.6Procedure : Operational Control (QAP-EH-007)

Bahra Cables Company fully integrates its EMS and OHSAS across its management system.

Bahra Cables Company makes arrangements for effective implementation of its EMS and OHSAS to ensure that activities are carried out safely and in accordance to legal and other requirements as the minimum.

Managers are responsible for indentifying their department’s activities and operations associated with significant environmental aspects and hazards.

Procedures / work instructions are established, maintained and effectively implemented for: • Planning and controlling their department activities and operations. • Maintenance of these activities and operations.

Bahra Cables Company established and maintained documented procedures to to identify the environmental aspects and hazards. The relevant requirements are communicated to suppliers and contractors.

Relevant department manager is responsible to design of work place, process, installations, machinery, etc including the adaption of human capabilities in order to eliminate or reduce the environmental aspects and hazards and their sources.

4.4.7 Emergency Preparedness and Response

EMS : Clause No. 4.4.7OHSAS : Clause No. 4.4.7Procedure : Emergency Preparedness and Response (QAP-EH-004)

Bahra Cables Company provides resources (equipment, devices, tools, trained personnel and alarm systems) required for preparedness and response to emergency situation and accidents.

Hazardous materials were identified and listed and also the procedures were established and maintained for controlling storage and use of these materials.

Emergency plans were established, documented and maintained to identify potential response to emergency situations, accidents and incidents and for preventing significant impacts, illness and injury that may associated with them.

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Accidents and emergency situations are recorded and reported for analysis and investigation.

Safety and health committee review and revise – where necessary – emergency preparedness and response plans in particular after the occurrence of emergency situations and accidents.

Emergency preparedness and response is periodically tested where practical.

4.5 CHECKING

4.5.1 Monitoring and Measurement for EMS 4.5.1 Performance Measurement and Monitoring for OHSASEMS : Clause No. 4.5.1 & Clause No. 4.5.2OHSAS : Clause No. 4.5.1Procedure : Monitoring and Measurement (QAP-EH-003

Bahra Cables Company has established and maintained documented procedures for the environmental and safety monitoring and measurements.

Relevant manager records the results of environmental and safety measurements to track the performance of the operations and to ensure the compliance with EMS and OHSAS objectives, targets, management programmes and operational criteria and the regulatory requirements.

Measurements have been conducted with calibrated measuring equipment and the calibration records are retained as records according to procedure “control of records”.

Measurement results are subjected to compliance evaluation by the relevant manager with limit of legislative and regulation directly after receiving it.

4.5.2 Evaluation of Compliance

EMS : Clause No. 4.5.3OHSAS : Clause No. 4.5.3Procedure : Evaluation of Compliance ( QAP-EH-011)

Bahra Cables Company should be able to demonstrate that it has evaluated complaints with legal requirements legislative and regulation directly after receiving it.

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4.5.3 Incident Investigation, Nonconformity, Corrective and Preventive Action

EMS : Clause No. 4.5.3OHSAS : Clause No. 4.5.3Procedure : Control of Nonconformities (QSP-OTM-001, QSP-OP-005)Corrective and Preventive Actions (QSP-QMS-003)Procedure : Incident investigation (QAP-EH-008)

Bahra Cables Company has established and maintained documented procedures to ensure that : • Nonconformances are handled and investigated. • Actions are taken to mitigate the consequences arising from accidents, incidents and nonconformance. • Corrective and preventive actions are appropriate to magnitude of the problem and commensurate with environmental impacts and hazards. • Causes of accidents, incidents and nonconformity are investigated so that appropriate corrective and preventive action can be taken to prevent recurrence and to continuously improve the system.

The concerned department manager is responsible for: • Investigation of the causes of nonconformance. • Taking action to mitigate any consequences arising from the nonconformance. • Initiation and competition of corrective or preventive action. • Confirmation of the effectiveness of corrective or preventive action taken.

Corrective actions procedure takes into account the following: • Analysis of the causes of nonconformity related to product, process and or environmental management system. • Identifying and documenting the corrective action. • Controlling the effectiveness of the approved corrective actions by QA Department.

Preventive actions are taken on the basis of: • Analysis of information available from EMS and OHSAS related processes, work and operations concession requests, audit results, records and environmental complaint records. • Potential nonconformity.

Corrective and preventive actions are documented properly, maintained and controlled according to control of records procedure.

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The Management Representative is provided with adequate information about the required / suggested preventive actions as inputs for management review meetings.

Management reviews are provided with adequate information of corrective and preventive actions.

Effectiveness of corrective and preventive actions is discussed in the management review meetings.

Records of accidents, incidents, nonconformances and corrective and preventive actions are maintained in accordance with “Control of Records” procedure.

4.5.4 Control of Records

EMS : Clause No. 4.5.4OHSAS : Clause No. 4.5.4Procedure : Control of Records (QSP-QMS-002)

Bahra Cables Company maintains environmental records in order to demonstrate conformance to specified requirements and the effective operation of EMS and OHSAS.

Bahra Cables Company makes sure that all environmental records are legible, stored and retained in such a way that they are readily retrievable in a suitable environment to prevent damage and to prevent loss.

Each department is responsible for identifying, collecting, accessing, organizing, maintaining and disposing its records in accordance with control of records procedure.

Retention times of EMS and OHSAS records are established and recorded, as in control of records procedure .

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4.5.5 Internal Audit

EMS : Clause No. 4.5.5OHSAS : Clause No. 4.5.5Procedure : Internal Audit (QSP-QMS-004)

Bahra Cables Company has established and maintained documented procedures for planning and implementing internal environmental audits in order to : • Verify compliance of EMS and OHSAS activities and related results with planned arrangements. • Determine the effectiveness of EMS and OHSAS in meeting Policy and objectives. • Provide information on EMS and OHSAS performance to the top management.

QA Department is responsible for establishing and implementing the internal audit annual plan.

Audits are scheduled according to the importance and status of the activities to be audited, the results of the previous audit.

QA department is responsible for establishing and implementing the internal audit annual plan according to internal audits procedure.

Internal audits are scheduled according to the importance and status of the activities to be audited.

Internal audit annual plan is approved by the Management Representative.

EMS and OHSAS functions are to be audited once a year at least to determine compliance with EMS and OHSAS policy and procedures.

Internal audits are performed by trained personnel who are independent of the function being audited.

Internal audits results are brought to attention of the responsible personnel in the area audited to take the necessary corrective action.

The Management Representative is provided with the results of internal audits and the effectiveness.

Audit results are recorded and maintained according to “Control of Records” procedure.

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4.6 MANAGEMENT REVIEW

EMS : Clause No. 4.6OHSAS : Clause No. 4.6Procedure : Management Review (QSP-EH-009)

Top management reviews and evaluates its EMS and OHSAS periodically in order to ensure its continual improvement.

A management committee, consisting of directors and managers from all key areas of Bahra Cables Company, meets regularly, at least once a year, to review EMS and OHSAS in order to ensure effectiveness in satisfying the requirements of EMS and OHSAS standards and Bahra Cables Company ’s stated policy.

Management review is carried out according to management review procedure.

Records of management review meetings are maintained in accordance with control of records procedure.

Management review may include the following: • EMS and OHSAS objectives. • EMS and OHSAS Policy, Plans and Program(s). • Environmental complaints. • Incidents and accidents and emergency preparedness. • Training requirements. • Internal / External audits. • Corrective and preventive actions. • Follow up actions from previous management reviews. • Recommendations for continual Improvement.

The results of the management review would involve: • Improvement of the effectiveness of the EMS and OHSAS • Resource needs.

Management review results are documented in accordance with “Control of Records” procedure.

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V. Manual Changes and Modifications Instructions

Requests of Manual changes are carried out in accordance to Document control procedure.

Management Representative is responsible for the approval of changes and modifications on EMS and OHSAS manual.

EMS and OHSAS manual is reviewed every 5 years unless earlier review is found to be necessary.

The status of each page of this manual is identified by its current issue, revision numbers and revision date. Each page may be revised up to five times before re-issuing.

In case that the total number of modified pages exceeds 20 % of the manual pages, the manual is re-issued.

The numbered copies of the manual which are mentioned in the manual distribution list are controlled copies and marked accordingly.

Cover page of the manual is marked by document control stamp as means of control. The other uncontrolled copies of the manual will not be updated.

Distribution of this manual is the responsibility of Management Representative.

Maintenance of the manual is the responsibility of each registered holder.

Revisions are issued as necessary by the Management Representative to the registered holders,who are responsible for including the revised pages in their respective manuals, and returning those rendered obsolete to QA Department.

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Ⅵ. Reference to Enviromental Standard: EMS 14001:2004 and Health &Safety Standard: OHSAS 18001:2007

Any references to Quality System Procedures relates to the current issue of that procedure as detailed in Master List - WD-QMS-002.

ClauseElement of ISO 14001:2004 and

OHSAS 18001:2007Main ControllingDocumentation

4.1

4.6

4.3.3

4.4.2

4.5.4

Quality Management System, Management Responsibility & Resources Managements

The E and OH&S Policy, Management System and organisation responsible for ensuring that all activities are carried out in an effective and economic manner are defined in the E and OH&S Manual and Departmental Profiles.

The E and OH&S Management System is reviewed once a year to establish and maintain its suitability and effectiveness.

E and OH&S objectives Planning, and programes

Appropriate training needs for personnel are identified on a continuing basis. The subsequent training is reviewed and recorded.

E and OH&S records are identified and maintained in a defined way to ensure effective operation of the quality system. Retention periods for E and OH&S records are specified. Contingency plans are in placed to ensure continued availability of key systems and data.

BCC-EH1

QAP-EH-009

QAP-EH-010

QSP-HR-001

QSP-QMS-002

4.4.5

Documentation Requirements

Documentation controlling all procedures is created, reviewed and approved prior to implementation. Subsequent changes are controlled in the same manner and master records of the documents are held to enable the status of documents to be verified.

QSP-QMS-001

4.5.3

Control of Nonconforming Product

Documentation controlling all procedures is created, reviewed and approved prior to implementation. Subsequent changes are controlled in the same manner and master records of the documents are held to enable the status of documents to be verified.

QSP-OP-005

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NOTE: The above is issued as a guide to define the main controlling documents and does not preclude the use of supporting documentation in the Integrated Environmental and Occupational Health and Safety Management System to address elements of the standard.

END OF THE MANUAL

ClauseElement of ISO 14001:2004 and

OHSAS 18001:2007Main ControllingDocumentation

4.5.3

Corrective & Preventive Action

Corrective action is undertaken continuously, by investigating nonconformances, analysing relevant data and instituting procedures to ensure that perceived problems are effectively resolved.

QSP-QMS-003QSP-OP-005

4.5.5

Internal Audits

Documentation controlling all procedures is created, reviewed and approved prior to implementation. Subsequent changes are controlled in the same manner and master records of the documents are held to enable the status of documents to be verified.

QSP-QMS-004

4.4.6 0perational Control QAP-EH-007

4.3.1 Hazards identification, risk assessment and control of OHSAS

QAP-EH-001

8.2.2 Environmental Aspects QAP-EH-002

4.5.2 Monitoring and Measurements QAP-EH-003

4.4.7 Emergency Preparedness and Response QAP-EH-004

4.3.2 Legal and other requirements QAP-EH-005

4.4.3 Communication, Participation and Consultation QAP-EH-006

4.4.6 0perational Control QAP-EH-007

4.5.3 Incident Investigation QAP-EH-008