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Safety, Health and Environment (SHE)
SHE Management Standards
February 2010 – ISSUE 2
The most important thing we build is trust
Safety, Health and Environment Management Standards
SHE – Issue 2
Contents
Foreword
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Safety, Health and Environment Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
SHE Performance Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
SHE Management Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1 Leadership and Management Commitment . . . . . . . . . . . . . . . . . . . . . . . . 4
2 Planning and Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
3 Risk Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4 Communication and Engagement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
5 Regulatory and Corporate Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
6 Monitoring and Assurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
7 Competency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
As a growing, dynamic, international company we recognise the importance
of developing a business that is sustainable economically and environmentally,
which is why we place great emphasis on Safety, Health and Environment
(SHE). The Cobham Board of executives has very clearly stated that one of our
most important goals is to achieve an injury and incident free business, and to
minimise the impact our business has on the environment.
We will work towards these goals through leadership, fostering a positive and
proactive SHE culture, clearly articulating the standards we aim to achieve.
The SHE Management Standards in this document establish our expectations
and focus on the following areas in particular:1 Demonstrating commitment to SHE
2 Ensuring compliance, as a minimum, with the regulatory requirements
where our businesses operate
3 Driving continuous improvement to meet and ultimately exceed leading
SHE practices
10 Continuous Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
For the past 75 years we have been proudly protecting lives and livelihoods
with our products and services. This is a great base to work from, so I am
confident that with your support we can extend this to everyone affected by
our operations, activities, products and services.
Figures
We hope that you will find these Standards useful in improving
SHE management in your business and we would appreciate
your feedback.
8 Incident Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
9 Emergency Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Figure 1 – Cobham’s SHE Management Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Andy Stevens
February 2010
Safety, Health and Environment Management Standards
SHE – Issue 2
Introduction
SHE Performance Levels
This document sets out the standardised management approach by
Cobham plc (the “Company”) to the management of safety, health
and environment (SHE) relating to its operations, activities, products
and services and forms part of the Corporate Framework. Words and
expressions defined in the Corporate Framework have the same meaning
when used in this CR&S Framework save that “Group” means corporate
functions, Divisions, SBUs and BUs.
The Company respects that its businesses have
varying levels of scale, resources, maturity and
risk associated with SHE. As such, the Company
has provided its businesses with three
increasing levels of performance to define their
behaviours and approach in relation to SHE.
LEVEL 3
World Class
Safety, Health and Environment Policy
The Company’s SHE policy is to strive to:
• Provide workplaces that are injury-free and
incident-free for all employees, visitors and
contractors.
• Enhance the well-being of its employees
and local communities.
• Where practicable, minimise its impact on
the local and global environment arising
from it operations, activities, products
and services.
To achieve this policy, the Group will
endeavour to provide the following:
• Demonstrated leadership and management
commitment to SHE.
• Appropriate leadership development and
training in SHE.
• Fostering and maintenance of a positive
SHE culture.
• Identification, assessment and elimination/
mitigation of all the risks associated with
SHE hazards in the Group’s operations,
activities, products and services.
• Continuous improvement towards meeting
and exceeding leading SHE practices.
• Elimination, mitigation or remediation
of the environmental impacts of the
Group’s activities.
• Continuous improvement on the efficiency
and use of raw materials, energy and
natural resources.
• Reduction in emissions of direct and
indirect greenhouse gases and assessment
of the need for adaptation of the Group in
relation to the significant adverse effects of
climate change.
• Reduction in the use of hazardous
substances.
• Reduction, reuse or recycling of wastes
wherever possible.
• Development and encouragement of a
just and equitable SHE reporting culture
that does not apportion blame such that
the Group can learn and share from SHE
accidents and high potential incidents.
• Preparation and effective response to SHE
emergencies and crises.
LEVEL 2
First Target
LEVEL 1
Foundation
Compliance/Risk
Management Driven
This level sets out the Company’s
foundation performance for a focus area.
Management will be required to meet this
performance level and correct any noncompliance identified on an urgent priority
basis with regulatory non-compliances
addressed as the highest priority.
Continuous Improvement
Driven
This is the first target level of performance
for each focus area. On achieving the
foundation level of performance, the
Company requires management to
develop a defined action plan to meet
the First Target level of performance. The
action plan will require a defined timetable
that is appropriate to each corporate
function, division, SBU, BU and site.
Opportunity Driven
This is a performance level that the
Company aspires to for the Group. It
is intended to develop competitive
advantage for the Company and raise
the bar for future performance level
setting. On achieving the First Target
level of performance, the Company
requires management to develop
a defined action plan to meet the
World Class level of performance.
The action plan will require a defined
timetable appropriate to each corporate
function, division, SBU, BU and site.
Further information is provided in the Corporate Framework and the Corporate Responsibility & Sustainability
(CR&S) Framework.
• Empowerment of the Group’s personnel
to take responsibility for SHE with respect
to their own, their colleagues and their
communities wellbeing.
• Active engagement with contractors,
suppliers and business partners, so that they
understand and respect the Company’s SHE
policies and Management Standards.
• Metrics for management at all levels to
continually review, assess and improve
performance.
SHE management globally will be driven
through the implementation of the
standardised SHE Management Approach and
the reader is referred to the SHE Management
Standards and associated guidance.
Andy Stevens
February 2010
Safety, Health and Environment Management Standards
SHE – Issue 2
SHE Management Standards
1 Leadership and Management Commitment
SHE management throughout the Company
will be driven through the implementation of
ten SHE Management Standards that define
the Company’s minimum expectations for
managing SHE (refer to Figure 1).
1
The SHE Management Standards define how
SHE risks and impacts are to be identified
and managed in accordance with a
continuous management and performance
improvement process.
Intent
The Group’s management will demonstrate
visible SHE leadership and management
commitment. They will address and pursue
SHE performance with the same priority as
other key areas of business performance,
and understand and execute their SHE
accountability.
Minimum Requirements
All leaders and managers across the Group will:
Detailed information on compliance with the
Standards is provided in the accompanying
SHE Management Standards Guidance
document, Issue 1.
1 Embrace and champion Group-wide SHE
policies and communicate them across
the business.
Leadership &
Management
Commitment
2 Develop a SHE policy that complies
with the requirements of the Company’s
SHE policies.
Monitoring &
Assurance
Communication
& Engagement
Incident
Management
Planning &
Resources
3 Promote a proactive, just and equitable
SHE culture that rewards success and does
not apportion blame.
4 Treat SHE management as important as
other key areas of business performance.
Risk
Management
Emergency
Management
Competency
Regulatory
& Corporate
Compliance
5 Endorse plans to bring the business
promptly into full compliance with the
Company’s SHE Management Standards
at the performance level adopted from
the CR&S Framework (i.e. Foundation, First
Target or World Class).
6 Commit to continuous improvement by
driving the business towards the next SHE
performance level in the CR&S Framework
or continuing to seek competitive
advantage through SHE opportunities once
World Class has been achieved.
7 Establish and document personal SHE
objectives and targets for themselves,
against which their performance will be
appraised. This should be cascaded to
staff in accordance with their key roles
and responsibilities.
8 Empower all employees to take
responsibility for SHE with respect to their
own, their colleagues’ and others’ (e.g.
contractors, community etc.) wellbeing.
9 Seek to drive improvements in SHE
performance using appropriate SHE
management techniques, including but
not limited to LEAN principles, processes
and tools.
10 When allocating resources, prioritise
resources for meeting the requirements
of these SHE Management Standards and
sustaining regulatory compliance.
11 Further their SHE leadership skills through
professional development in both technical
and managerial aspects of SHE.
12 Consult with key stakeholders of the
business to understand their SHE concerns
and aspirations, in a culturally sensitive and
appropriate manner.
Continuous Improvement
Figure 1 – Cobham’s SHE Management Standards
Safety, Health and Environment Management Standards
SHE – Issue 2
2 Planning and Resources
Intent
2
The Group will manage the impacts of its
operations, activities, products and services
at all levels of the organisation through
establishing effective SHE planning processes
that integrate with its other business planning
processes. SHE will be given equal priority
to all other business planning requirements.
The Group will identify and provide sufficient
human, financial and technical resources
to ensure regulatory compliance, manage
significant SHE risks and impacts, and deliver
on its continuous improvement goals.
Minimum Requirements
The Group will:
1 Appoint a senior manager with overall
accountability for SHE management.
2 Develop and communicate annual SHE
plans, objectives and targets to deliver
identified improvements at all levels, in line
with the intent of the CR&S Framework,
Continuous Improvement standard (i.e.
Standard 10) and aligned to the Company’s
objectives and targets.
3 Define SHE roles, responsibilities and
accountabilities for developing and
delivering SHE plans and all other aspects
of SHE management described in the SHE
Management Standards.
3 Risk Management
4 Establish a SHE organisation to develop SHE
plans, champion continuous improvement
and promote a proactive, just and equitable
SHE culture.
5 Define leading and lagging SHE metrics
which, as a minimum, incorporate the
Group-wide SHE metrics and supplemented
with any locally applicable metrics to
drive local performance improvement.
The Company will collect performance
data from across the Group to enable
monitoring of performance and
programmes and to meet the Company’s
legal reporting obligations.
6 Review progress against the SHE plans
at least annually (see also Standard 6:
Monitoring and Assurance).
7 Allocate sufficient human, financial
and other resources (including external
specialist, competent advice) necessary
at all levels to implement the SHE Policy,
meet the requirements of the CR&S
Framework and the SHE Management
Standards to deliver sustained regulatory
compliance and deliver on SHE continuous
improvement plans
Intent
3
Cobham will manage the SHE risks of its
operations, activities, products and services
at all levels of the organisation, through
systematic risk identification and elimination
(where practicable) or mitigation. Risks will
be identified and tracked and the potential
consequences understood, communicated
and addressed in business planning processes.
Minimum Requirements
The Group will:
1 Establish and maintain procedures to
systematically identify and document
SHE hazards and impacts associated with
their operations, activities, products
and services.
2 Assess SHE risks arising from the identified
hazards by applying recognised analytical
and evaluation methodologies.
3 Select and implement effective control
measures consistent with the recognised
‘hierarchy of controls’ to prevent, eliminate
or reduce risks and impacts.
4 Identify particularly high risk activities
and develop and implement documented
procedures for managing such activities.
5 Develop a means of tracking SHE
control measures through to effective
implementation.
6 Develop a change management process
to identify SHE risks associated with
significant changes and put in place
appropriate controls to eliminate or
mitigate the associated risks.
7 Periodically review identified SHE risks to
ensure understanding and control of risks is
up-to-date.
8 Establish a means of communication to
employees, contractors and visitors on
identified risks and adopted risk controls.
9 Develop and implement contractor
management processes to identify, assess
and manage SHE risks as a minimum on
high risk contracts.
8 Ensure planned SHE requirements are
included and visible in budgeting requests.
The Group will consider requests for SHE
capital and operating expenditure with
equal priority to all other business
planning requirements.
Safety, Health and Environment Management Standards
SHE – Issue 2
4 Communication and Engagement
Intent
The Group will communicate their SHE
expectations, risks and performance in
an effective and timely manner to their
employees, visitors and contractors and
will engage with employees, visitors and
contractors to continuously improve SHE
awareness, commitment and competency.
4
Cobham will identify and respond to its
key external stakeholder concerns and
needs in relation to the impacts of the
Group’s activities, operations, products and
services on society and the environment.
Communication will be conducted in an
equitable and culturally sensitive manner, to
promote engagement across all geographies
and cultures.
Minimum Requirements
The Group will:
1 Ensure effective channels of
communication exist to:
i appropriately inform all employees, visitors
and contractors of the business’s SHE
policies and objectives, and
6 Monitoring and Assurance
2 Ensure senior managers communicate
and engage directly with employees (in
person) on a regular basis regarding SHE
management and performance.
3 Invite employee representatives to
participate in local SHE committees.
4 Regularly engage with employees to
understand their material concerns and
needs with regard to SHE and provide
feedback as to how the business is
addressing these concerns and needs.
5 Engage with contractors to assess their
ability to comply with the business’s SHE
policies and objectives.
6 Communicate and engage with regulatory
bodies as appropriate to maintain SHE
regulatory compliance.
7 Establish, implement and maintain a
process to identify and periodically
review the business’ key external
stakeholders associated with SHE aspects
of their operations, activities, products
and services.
5
The Group will, at all times, meet the law as
it applies in each location that it operates in
and abide by the SHE requirements set out in
the Corporate Framework, Code of Business
Conduct, CR&S Framework, SHE Policies and
SHE Management Standards that might be
revised, developed or added to from time
to time.
Minimum Requirements
The Group will:
1 Identify all SHE legislation, recognized
voluntary standards (e.g., ISO and ANSI
standards) and codes of practice and
corporate requirements (hereinafter all
referred to as “the requirements”) that are
applicable to their operations, activities,
products and services.
6
The Group will monitor SHE performance
and undertake routine management reviews
to assess the adequacy and effectiveness of
their SHE policies, systems and performance.
Actions will be taken to address weaknesses
and share good performance across the
organisation. The Group will identify areas for
improvement in SHE performance as required
to progress the business to the next level in
the CR&S Framework.
In accordance with the requirements of the
Corporate Framework, the Company will seek
assurance of the Group’s SHE performance
and management effectiveness through a
combination of self-assessment, independent
internal audit and external audit.
Minimum Requirements
The Group will:
1 Develop leading and lagging metrics for
management to continually review and
assess the adequacy of SHE management
and performance.
2 Develop a periodic monitoring and
assurance programme that provides
feedback to senior managers, at an
appropriate frequency, regarding their:
i regulatory compliance status;
5 Regulatory and Corporate Compliance
Intent
Intent
ii provide the Company with regular updates
on SHE performance.
2 Identify changes to the requirements
at a frequency appropriate to maintain
compliance.
3 Create and maintain a register of
applicable requirements.
ii conformance to the Company’s
SHE policies and SHE Management
Standards;
3 Evaluate employees SHE behaviours and
culture and implement change, where
required, to deliver the desired SHE
behaviours and culture.
4 Establish and maintain auditable evidence
of SHE performance to meet the
requirements of the SHE Management
Standards and the Company’s SHE
reporting requirements.
5 Implement processes to control and
routinely audit contractors’ and key
suppliers’ SHE performance at frequencies
appropriate to their SHE risks and
performance, and act upon audit findings
to improve their SHE performance.
6 Establish and maintain an effective system
for tracking close-out of corrective and
preventative actions including for incidents.
7 Perform an annual self-assessment of SHE
performance against the requirements
of the performance level adopted from
the CR&S Framework and the SHE
Management Standards guidance.
8 Participate fully, when requested by the
Company, in an independent assurance
audit involving an independent Cobham or
external resource.
9 Conduct an annual management review
to assess all findings from the monitoring
& assurance programme & determine the
suitability and effectiveness of
SHE management.
iii effectiveness and implementation of
risk controls; and
iv progress against objectives and targets.
4 Determine how identified new or amended
requirements apply to the business and
what action is needed to comply.
5 Assign accountability for implementing
those actions, and communicate to those
assigned what is needed to comply.
6 Document that the actions needed to
deliver compliance have been completed.
7 Report and investigate non-compliance and
take action to prevent reoccurrence.
Safety, Health and Environment Management Standards
SHE – Issue 2
7 Competency
8 Incident Management
Intent
7
The Group will ensure that all employees
(including senior management) are competent
to carry out their work activities and to
manage significant SHE risks and impacts and
provide the platform for achieving continuous
improvement. Employees will be provided with
the necessary experience, skills and training to
achieve the required level of competency for
their work activities.
Minimum Requirements
The Group will:
4 Identify competency needs necessary to
deliver regulatory compliance, identify and
manage risks, drive continual improvement
and establish a proactive, just and equitable
SHE culture.
5 Where necessary, implement a training
programme to deliver the required
competencies in a timely manner.
6 Assess contractors and suppliers (before
being appointed) to ensure they have the
required SHE competencies appropriate to
the scope of work being undertaken.
1 Actively manage and promote proactive
SHE behaviours amongst their employees,
particularly those with SHE related roles
and responsibilities.
7 Ensure training and competency records
are documented and stored in a manner
appropriate to ensure accessibility by
relevant personnel whilst protecting
employee confidentiality.
2 Consider SHE competencies as key
selection criteria during the recruitment
process of new (or return to work)
employees who are primarily engaged in
SHE-related activities.
8 Seek independent specialist, competent
advice (either from within or outside of
the Group) where internal resources are
insufficient to manage SHE risks and deliver
SHE plans, objectives and targets.
3 Conduct periodic SHE performance
evaluations for staff with SHE
responsibilities.
8
Intent
Minimum Requirements
Cobham’s goal is to provide an injury-free
and incident-free working environment for
all employees, visitors and contractors. The
Group will develop a just and equitable SHE
reporting culture, routinely analyse the causes
of SHE accidents and high potential incidents,
implement corrective actions and track them
to completion. Investigations of high severity
and high potential incidents will include a
thorough understanding of the root cause
and lessons learnt will be shared throughout
the Group.
The Group will:
1 Develop a just and equitable SHE reporting
culture such that employees report
accidents and near misses without fear
of reprisal.
2 Report SHE accidents and incidents to the
Company in accordance with Company’s
reporting requirements (i.e. quarterly H&S
metrics and annual CR&S returns).
3 Report SHE accidents through the
operational management structure as
appropriate to the severity of the incident.
4 Report all SHE accidents and incidents
to the local regulatory authority in
accordance with applicable regulatory
reporting requirements;
5 Investigate SHE accidents and high
potential incidents to identify underlying
causes and contributory factors towards
identifying and implementing corrective
and preventative actions.
6 Invite a Divisional or Company manager to
lead incident investigation and reporting
into any accidents that have the potential
for severe injury, if they occur.
7 Maintain records of all SHE accidents and
high potential incidents.
8 Implement a process for the sharing of
lessons learnt from incident investigations
across the Group.
10
11
Safety, Health and Environment Management Standards
SHE – Issue 2
9 Emergency Management
Intent
9
Cobham will ensure appropriate measures
are taken to prevent SHE emergencies. The
Group will prepare for, and provide, effective
resources and responses to SHE emergencies
impacting the Group’s operations, activities,
products and services.
Minimum Requirements
The Group will:
1 Develop and document site-specific
emergency response plans at their
operating locations that includes
consideration of all potential SHE
emergency situations and their impact
on the business, the environment and
surrounding communities.
2 Consult with local communities, emergency
services and external regulatory authorities
as appropriate during the development of
an emergency response plan.
10 Continuous Improvement
3 Define roles and responsibilities for
developing and implementing the
emergency response plan.
4 Allocate sufficient human, financial and
other resources necessary to implement
the emergency response plan.
5 Ensure that emergency plans are consistent
with, and integrated with, the Group’s crisis
management and business continuity plans.
6 Conduct emergency response drills on a
periodic basis (at least annually) to review
the effectiveness of emergency response
arrangements and update the plan
accordingly.
7 Ensure the emergency response plan is
communicated and made available to
employees, visitors, contractors and other
interested parties (e.g. emergency services
and local communities) where relevant
and appropriate.
10
Intent
Minimum Requirements
Cobham will strive for continuous
improvement in SHE performance in all its
operations, activities, products and services
and apply all relevant and appropriate
SHE management techniques (including
application of LEAN techniques, tools and
processes) to optimise SHE performance and
key stakeholder value.
The Group will:
The Group will identify and implement areas
for improvement in SHE performance as
required to:
2 Through implementing the Planning and
Resources Standard (i.e. Standard 2),
develop plans and measurable objectives
and targets to drive achievement of the
identified improvements.
i
ensure sustained compliance with
regulatory requirements; and
ii reduce impacts on people (including but
not limited to employees, visitors and
contractors) and the environment.
1 Identify improvements that will i) deliver
full conformance with their adopted level
of performance in the CR&S Framework
and ii) drive progress to the next level
of performance in the CR&S Framework
in accordance with an action plan and
timeline defined for each business.
3 Assign accountability for achieving
improvements.
4 Periodically review SHE performance,
define improvement goals and visibly
commit, through leadership and providing
the necessary resources, to achieving
those goals.
5 Ensure that SHE is considered in all stages
of design, manufacture, use and disposal
of our products and services with a view to
continuously improving their performance
and impacts (e.g. energy consumption,
raw material and hazardous substance use,
waste generation etc).
12
13
Leadership &
Management
Commitment
Monitoring &
Assurance
Planning &
Resources
Communication
& Engagement
Risk
Management
Incident
Management
Emergency
Management
Competency
Regulatory
& Corporate
Compliance
Continuous Improvement
For further information:
James Streater
Director, Corporate Responsibility & Sustainability
E: [email protected]
Cobham plc
Brook Road
Wimborne
BH21 2BJ
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