ZC COP EHS12 Compliance Enforcement

8/12/2019 ZC COP EHS12 Compliance Enforcement

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Higher Corporation for Specialized Economic Zones

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CODE OF PRACTICE ONCOMPLIANCE ENFORCEMENTZonesCorp CoP EHS 2

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COMPLIANCE ENFORCEMENT

Document No ZC-COP-EHS12 Rev. No. 0 Date of Issue 21 Sept. 2008

Page 2 of 34Industrial Sector Environment Health & Safety Regulatory Framework

REVISION HISTORY

Rev. No. Issue Date Revised Section Revision Description

0 New document

Copyright

The copyright and all other rights of a like nature in this document are vested in Higher Corporation forSpecialized Economic Zones (ZonesCorp), Abu Dhabi, United Arab Emirates. This document is issuedas part of the Industrial Sector EHS Regulatory Framework and as guidance to Industrial Sector withinthe Abu Dhabi Emirates. Any party within Industrial Sector may give copies of the entire EHSDocuments or selected parts thereof to their contractors/consultants for implementation of EHSManagement Standards. Such copies should carry a statement that they are reproduced bypermission of ZonesCorp and an explanatory note on the manner in which the document is to be used.

Disclaimer

No liability whatsoever in contract, tort or otherwise is accepted by ZonesCorp or any party whether ornot involved in the preparation of the EHS Management System Documents for any consequenceswhatsoever resulting directly or indirectly from reliance on or from the use of the ZonesCorp EHSDocuments or for any error or omission therein even if such error or omission is caused by a failure toexercise reasonable care.

All administrative queries should be directed to the ZonesCorp EHSMS Administrator HSE Division

Higher Corporation for Specialized Economic ZonesP.O. Box: 36000, Abu Dhabi,United Arab Emirates.Telephone: (9712) 5073358Fax: (9712) 5073564Internet site: www.zonescorp.comE-mail: [email protected]


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TABLE OF CONTENTS

1 PURPOSE 4

2 SCOPE 5

3 DEFINITIONS 6

4 EXISTING APPLICABLE LAWS 8

5 RESPONSIBILITIES 10

6 PRINCIPLES OF ENFORCEMENT 12

7 THE ENFORCEMENT PROCESS 16

8 REFERENCES 22

9 ANNEXURE 1: LIST OF EHS CODES OF PRACTICE 23

10 ANNEXURE 2: LIST OF PENALTIES FOR NON-COMPLIANCE 25

11 ANNEXURE 3: TEMPLATE FOR ENFORCEMENT NOTICE 34


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1 PURPOSE

Based on the power vested by the Executive Council of Emirates of Abu Dhabion the EHS Higher Committee, it has designated Higher Corporation forSpecialized Economic Zones ZonesCorp as the EHS Regulatory Authorityfor the Industrial Sector within Abu Dhabi Emirate. Also the Executive Councilhas designated the Environment Agency Abu Dhabi (EAD) as the CompetentAuthority of EHS Management within Abu Dhabi Emirate. ZonesCorp in itsRegulatory Role is the enforcement agency for the Entities within IndustrialSector while interacting with the concerned Govt. Agencies (EAD, CivilDefense etc.) for fulfilling the applicable regulatory requirements like EHS

Permitting etc.

The provisions of the Federal Law No. 24 and Abu Dhabi Emirate EHS Lawhave outlined the mechanism of Protection & improvement of the Environment.The EHS law also has clearly established the principle of self regulation byentities.

A legal instrument to establish the enforcement mechanism and to define thepolicy and approach has lead to the development of this ZonesCorp EHSCode of Practice. The purpose of this Code of Practice is to outline theEnvironmental Health & Safety requirements Enforcement Policy. The

objectives of the Enforcement Policy are:

a. To ensure that those on whom the laws places duties (duty holders)take action to deal immediately with serious risks;

b. To promote and achieve sustained compliance with the laws;

c. To ensure that duty holders who breach environment, health and safetyrequirements, and owner or the management of the entity who fail intheir responsibilities can be held accountable which may includebringing alleged offenders before the courts.

The purpose of this document is to set out the Enforcement Policy by whichZonesCorp on behalf of the EHSMS Higher Committee for the Emirate of AbuDhabi ensures compliance with Environment, Health & Safety legislation. Thepurpose of the policy is to ensure that enforcement decisions are alwaysconsistent, balanced, fair, targeted, accountable, transparent, proportional andrelates to common standards to ensure no harm to people, environment,property and the public at large is adequately protected.

The ultimate aim of ZonesCorp is to ensure that duty holders manage and actto control risks effectively, thus preventing any harm to people, environment,property and the public at large.


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2 SCOPE

These requirements are applicable to the Entities including but not limited toindustrial units / facilities / commercial operations / workshops / warehouse /residential cities/ labour camps / construction work sites within the IndustrialSector in the Abu Dhabi Emirate. These include Industrial Cities but not limitedto Abu Dhabi Industrial Cities (ICADs), Al-Ain Industrial Cities (AAICs) andother Entities (Industries / residential cities / commercial operations etc.) withinIndustrial Sector in the Abu Dhabi Emirates.

The enforcement action would be enforced by ZonesCorp EHS Specialist /

Inspectors based on their best professional judgement and shall be final.

Wherever possible, and rather than providing detail within this document,reference is made to other, more detailed documents that have been providedin the ZonesCorp EHS Management System.


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3 DEFINITIONS

3.1 ACGIH: American Conference of Government Industrial Hygienists

3.2 BEIs : Biological Exposure Indices

3.3 CEMP: Construction Environment Management Plan

3.4 CHSMP: Construction Health & Safety Management Plan

3.5 CoP: Code of Practice

3.6 Construction and Demolition Waste: Waste arising from construction,repair, maintenance and demolition of buildings and structures. Can

sometimes contain hazardous wastes such as asbestos.3.7 Duty Owner: Those on whom the law places duties e.g. the Owner / Chief

Executive Offices / Chief Operation Offices / Plant or Factory Manager of theentity.

3.8 Duty Of Care:A policy which requires all persons who have responsibility forwaste to ensure that it is managed properly and recovered or disposed ofsafely.

3.9 EAD: Environment Agency Abu Dhabi

3.10 ECAP: Environmental Compliance Action Plan

3.11 Entity: Facilities within Industrial Sector including Industrial, CommercialResidential and Welfare

3.12 EHS: Environment Health & Safety

3.13 EHS Construction Permit: Issued after review and approval of CEMP,CHSMP, FSP & TMP and valid for a period of 1 Year

3.14 EHSMS Environment Health & Safety Management System

3.15 EHS Operation Permit: Issued after review and approval of OEMP, EHSMS,WMP, ERP & ECAP and valid for a fixed duration to be renewed thereaftersubject to compliance conditions.

3.16 ESP: Environment Service Provider approved by EAD

3.17 Fixed Penalty Notices : A written notice served to an entity identifying theEHS noncompliance and the financial penalty to be paid within the stipulatedtime frame

3.18 Flora: Any vegetation including plants, trees, etc.

3.19 Fauna: Includes flora & faunas, insects, reptiles, marine life etc.

3.20 FRMP: Fire Risk Management Plan

3.21 Hazardous Waste: Wastes may be defined as hazardous on the basis of

waste characteristics (e.g. Flammable, Ignitable, Toxic, Mutagenic, Reactive,Corrosive, etc.) or waste may be defined as hazardous on the basis of 'Listing'


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(i.e. are any components of the waste stream listed as hazardous; in

Hazardous Waste Regulation).3.22 IETP: Industrial Effluent treatment Plant

3.23 Improvement Notices: A written notice served to an entity identifying the EHSnoncompliance and suggesting the required improvement within prescribedtime frame

3.24 Industrial Sector: Industrial Sector within Abu Dhabi Emirate includes but notlimited to Entities (Industrial Units etc.) in Industrial Cities developed byZonesCorp, Industrial Areas like Mussafah, Mafraq, etc. and WorkersFacilities (Labour Camps) for Industrial Sector

3.25 IOSH:Institute of Occupational Safety & Health3.26 KPI: Key Performance Indicators are a measure (or benchmark) of

performance of a particularly activity with reference to applicable standardsand timescales for frequency of measurement.

3.27 LEV :Local Exhaust Ventilation

3.28 NIOSH:National Institute Occupational Safety & Health

3.29 OEMP: Operation Environment Management Plan

3.30 OHSMP: Operation Health & Safety Management Plan

3.31 OSHA: U. S. Occupational Safety & Health Administration

3.32 OSS: ZonesCorp One Stop Shop

3.33 PELs : Permissible Exposure Limits

3.34 Prohibition Notices: A written notice served to an entity identifying the EHSnoncompliance and requiring offender to cease contravening activities, givingoffender reasonable time to rectify a contravention

3.35 RELs : Recommended Exposure Limits

3.36 Tenant:Project Proponent /Lease Holder / Concession Agreement Holder /Owner / Operator of an entity within the Industrial Sector in Abu Dhabi Emirate

3.37 TMP: Transport Management Plan

3.38 TLVs : Threshold Limit Values

3.39 WMP: Waste Management Plan

3.40 Worker: Personnel primarily working in Industrial Sector within Abu DhabiEmirate, including but not limited to Abu Dhabi Industrial Cities (ICADs), Al-AinIndustrial Cities (AAICs) and Mussafah Industrial Area, Worker ResidentialCities, Labour Camp, as well as contractor personnel etc.

3.41 ZonesCorp: Higher Corporation for Specialized Economic ZonesDevelopment


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4 EXISTING APPLICABLE LAWS

All Tenants shall ensure that their operations comply with all relevant UAE andAbu Dhabi Environmental, Health and Safety laws and regulations.Environmental, Health and Safety regulations in the UAE are gradually beingimplemented.

This Code of Practice has been developed to ensure compliance to or exceedthe requirements of all relevant legislative statutes and regulations, specificallyincluding but not limited to:

4.1 Federal EHS Laws and Codes including UAE Standards Industrial Safety &

Health Regulations (Emirates Authority for Standardization & Metrology)4.2 Local Law No. ( ) of 2008 concerning Environment Health & Safety

Management System in Abu Dhabi Emirate

4.3 Local Law No. 16 of 2005; Article 14 Establishment or Individual is prohibitedto carry out any activity that could adversely affect the lives of human beingsand the safety of the environment before obtaining a license from the Agency.

4.4 Local Law No. 21 of 2005 on the Waste Management in Emirate of Abu Dhabi

4.5 Local Law No. 23 of 2005 and the Executive Regulations Regarding the HealthInsurance Scheme for the Emirate of Abu Dhabi

4.6 Federal Law No. 1 of 2002 Regarding Organisation & Monitoring the Use ofRadiation Resources and Protection

4.7 Federal Law No. 8 of 1980. The Labor Law (as amended 1986)

4.8 Federal Law No. 23 of 1999 Marine Bio-Resources in the UAE

4.9 Federal Law No. 24 of 1999 for the Protection & Development of the Environment

4.10 Regulations / Executive Ordersmade under the Federal Environment Law

a. Federal Bylaw; Protection of Air from Pollution (Ministerial Order # 12 of2006)

b. Federal Bylaw; System for Protected AreaMinisterial Decree No. 37 of 2001 concerning the approval of the ExecutiveOrders for Law No. 24. It includes the following Regulations:

a. Environmental Impact assessment of Projects 2001

b. Assessment of Environmental Effects of Installations 2001

c. Protection of the Marine Environment 2001

d. Handling Hazardous Materials, Hazardous Wastes & Medical Wastes 2001

e. Pesticides, Agricultural Additives and Fertilizers 2001


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4.11 Ministerial Decrees & Decisions:

a. Decree No. 50/2003 Basic Regulating Rules for Ionizing RadiationProtection

b. Decree No. 55/2004 Basic Regulations for Protection against IonizingRadiation.

c. Decree No. 56/2004 Basic Regulations for Safe Transport of RadioactiveMaterials

d. Decree No. 57/2004 Basic Regulations for Radioactive Waste Management

e. Decree No. 214/2004 on Use of Sludge on Land

f. Ministerial Order No.32/1982 on the Determination of Preventative

Methods and Measures for the Protection of Labor from Risks at Work4.12 Abu Dhabi Emirate Environment Protection Policies (EEPPs)

a. Part 1 Air Quality

b. Part 2 Water Quality

c. Part 3 Land Quality

d. Part 4 Noise

e. Part 5 Waste

f. Part 6 Hazardous Substances

g. Part 7 Occupational and Environmental Health & Safety

h. Part 8 Biodiversity and Conservation

4.13 Abu Dhabi Emirate Environment Protection Policies Standards

a. Part 1 Air Quality Standard

b. Part 2 Water Quality Standard

c. Part 3 Land Quality Standard

d. Part 4 Noise Quality Standard

4.14 Abu Dhabi Emirate EHS Management System Codes of Practices

a. Self Regulation

b. Roles & Responsibilitiesc. Risk Management

d. Audits & Inspection

e. Emergency Management

f. Monitoring and Reporting

g. Management Reviews

4.15 EAD Regulations on Hazardous Material & Waste Permit

4.16 Industrial Safety and Health Regulations Occupational Health andEnvironmental Control SSUAE No. 209 / 1995.


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5 RESPONSIBILITIES

5.1 Competent Authority

The Competent Authority (EAD) in cooperation with the Regulatory Authority(ZonesCorp) shall approve the types of entities (targeted entities) that shoulddevelop & implement an EHSMS in accordance with the Abu Dhabi EmirateEHS Law.

The Competent Authority (EAD) shall set mechanisms for:

Reviewing and approving EHSMS developed by Entities to ensurecompliance with the requirements of the EHSMS at Abu Dhabi Emirate

level.

Auditing the EHSMS implemented by different entities.

The Competent Authority (EAD) shall promote the importance of implementingthe EHSMS.

The Competent Authority (EAD) shall be responsible for reporting to theExecutive Council the performance of the EHSMS at Abu Dhabi Emirate level.

5.2 Regulatory Authority

The Regulatory Authority (ZonesCorp) in cooperation with the CompetentAuthority (EAD) shall identify the types of entities that should develop &implement an EHSMS in accordance with the Abu Dhabi Emirate EHS Law.

The Regulatory Authority (ZonesCorp) in cooperation with the CompetentAuthority (EAD) shall implement mechanisms for:

Reviewing and approving EHSMS developed by entities in compliance tothe requirements of the Abu Dhabi Emirate EHSMS.

Auditing the EHSMS implemented by different entities.

Receiving EHSMS Performance from Industrial Sector Entities

Compilation and reporting EHSMS Performance of Industrial Sector to the

Competent Authority (EAD)The Regulatory Authority (ZonesCorp) in cooperation with the CompetentAuthority (EAD) shall promote the importance of implementing the EHSMS.

5.3 Entities

5.3.1 Entities shall develop and implement an EHSMS within their areas ofjurisdiction to protect their employees, the community and the environmentfrom any adverse impacts arising from their activities.

5.3.2 Entities shall provide and maintain a safe environment for workers, avoid anyrisk to human health, avoid adverse impact to environment and prevent

environmental pollution.


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5.3.3 Entities having an EHSMS are required to audit their System in order to

ensure conformance with ZonesCorp EHSMS Requirements.5.3.4 Entities having established an EHSMS are required to demonstrate self

regulation.

5.3.5 Entities having an EHSMS are required to submit an annual report to theZonesCorp / EAD on the performance of their System as per the mechanismset by ZonesCorp.

5.4 Employers Duties

5.4.1 Employers have the ultimate responsibility to ensure the health and safety oftheir employees.

5.4.2 Employers have a general Duty of Care to take all practicable steps to ensurethe safety of their employees while at work, visitors and contractors.

In particular, they are required to take all practicable steps to:

Provide and maintain a Safe Working Environment;

Provide and maintain facilities for the Safety and Health of employees atwork;

Ensure that machinery and equipment are safe;

Ensure that working arrangements are not hazardous to employees; and

Ensure a Safe System of Work comprising at least of Procedure, Training,

Communication & Supervision is in place

Ensure procedures are available to deal with emergencies that may arisewhile employees are at work.


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6 PRINCIPLES OF ENFORCEMENT

6.1 General

Enforcement of environmental, health and safety requirements should only beundertaken for the purposes of:

a. Better protecting the environment and its economic and social uses;

b. Ensuring that no commercial advantage is obtained by any person who fails tocomply with environmental and/or health and safety requirements; and

c. Influencing the attitude and behaviour of persons whose actions may haveadverse environmental, and/or health and safety impacts, or who develop,

invest in, purchase or use goods and services which may have adverseenvironmental and/or health and safety impacts.

ZonesCorp as the Industrial Sector EHS Regulatory Authority is committed tothe principles of self regulation and good enforcement of all Federal as well asLocal EHS Laws and regulations including the requirements of the ZonesCorpEHS Code of Practices. ZonesCorp believes in strong, fair and effectiveenforcement of Environment, Health and Safety regulations.

In line with the policy of self regulation as per the EHS law, entities havingestablished an EHSMS are required to demonstrate self regulation, failingwhich if the regulatory authority (ZonesCorp) may find an EHS non

conformance will take enforcement action against the entity.ZonesCorp has a range of tools at their disposal in seeking to securecompliance with the regulations. ZonesCorp EHS Specialists / Inspectors mayprovide duty holders information, both face to face and in writing. This mayinclude warning a duty holder that in the opinion of the inspector, they arefailing to comply with the regulations. Where appropriate, ZonesCorp EHSSpecialists / Inspectors may also serve improvement and prohibition notices,issue formal cautions or revoke EHS Permit / Licence

Giving information, issuing improvement or prohibition notices are the mainmeans which inspectors use to achieve the broad aim of dealing with serious

risks, securing compliance with environment, health and safety regulations andpreventing accidents. A prohibition notice stops work in order to preventserious personal injury or anything that may be cause immediate danger to lifeor health. Information on improvement and prohibition notices shall be madepublicity available.

Every improvement notice / prohibition notice / fixed penalty notice contains astatement that in the best professional judgement of the ZonesCorp EHSSpecialists / Inspectors a non-compliance has been committed.

Investigating the circumstances in presence of the entity representativeencountered during audits, inspections or following incidents or complaints is

essential before taking any enforcement action.


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ZonesCorp EHS enforcement will follow the following principles:

6.1.1 ProportionalityProportionality means relating enforcement action to the risks.

In practice, applying the principle of proportionality means that ZonesCorp asthe Industrial Sector EHS Regulatory Authority shall take particular account ofhow far the duty holder has fallen short of what the regulations requires andthe extent of harm to the environment or the extent of the risks to the peoplearising from the breach.

Where duty holders must control risks so far as is reasonably practicable,ZonesCorp consider protective measures taken by duty holders, shall takeaccount of the degree of risk on the one hand, and on the other the reasonablepracticability, whether the money, time or trouble, involved in the measures isnecessary to avert the risk. Unless it can be shown that there is grossdisproportion between these factors and that the risk is insignificant in relationto the cost, the duty holder must take measures and incur costs to reduce therisk. The ZonesCorp specialist's decision on the extent of risk or potentialharm to people asset and environment shall be the final.

ZonesCorp will expect relevant good practice to be followed. Where relevantgood practice in particular causes is not clearly established, health and safetyregulations effectively requires duty holders to establish explicitly thesignificance of the risks to determine what action needs to be taken.

Some irreducible risks may be so serious that they cannot be permittedirrespective of the consequences or any kind of rational being put forward bythe duty holder.

6.1.2 Consistency

Consistency of approach does not mean uniformity. It means taking a similarapproach in similar circumstances to achieve similar ends.

Duty holders managing similar risks expect a consistent approach fromZonesCorp in the use of enforcement notices, penalties and in the response toincidents.

ZonesCorp as the Industrial Sector EHS Regulatory Authority recognizes thatin practice consistency is not simple matter. ZonesCorp EHS Specialists /Inspectors may face with many variables including the degree of risk, theattitude and competence of management, EHS audit / inspection findings,EHS performance reports, any history of incidents or breaches involving theduty holders, previous enforcement action, and the seriousness of any breach,which includes any potential or actual harm arising from a breach ofregulations. Decisions on enforcement action are discretionary by the enforcer(ZonesCorp EHS Specialists / Inspectors).

ZonesCorp as the Industrial Sector EHS Regulatory Authority shall have

arrangements in place to promote consistency in the exercise of discretion,


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including effective arrangements for liaison with other enforcing authorities

(EAD, Civil Defence, Municipality etc.).6.1.3 Transparency

Transparency means helping duty holders to understand what is expected ofthe entities and what they should expect from the ZonesCorp as the IndustrialSector EHS Regulatory Authority. It also means making clear to duty holdersnot only what they have to do but, where this is relevant, what they dont. Thatmeans distinguishing between statutory requirements and advice or guidanceabout what is desirable but not compulsory.

When ZonesCorp EHS Specialists / Inspectors offer duty holders information,face to face or in writing, including any warning, ZonesCorp EHS Specialists /

Inspectors will explain the duty holder what needs to be done to ensurecompliance to the EHS Laws and regulations, and why.

6.2 Enforcement Actions

An enforcement action would be preceded by a routine audit / inspectionfinding of EHS non-compliance or a poor EHS performance report or a follow-up investigation of an EHS incident including accidental release orenvironmental discharge.

The possible outcomes of an inspection or investigation are: -

Take no action only verbal warning

Take informal action issuing written warning / improvement notice

Use prohibition notices, equipment seized, premises closed etc.

Refusal / revocation of EHS licence / permit

Fixed penalty

Recommend legal action

These actions are discussed in further detail in Section 7 of this Code ofPractice. It may be that one or more of these outcomes would be appropriatein any given case.

In the case of improvement notices the ZonesCorp EHS Specialists /Inspectors will discuss the notice and, if possible serving it. The improvementnotice will explain that in the ZonesCorp EHS Specialists / Inspectors haveobserved a breach of the difference has been committed, what needs to bedone to comply with the regulations and by when.

In the case of a prohibition notice the ZonesCorp EHS Specialists /Inspectors will explain the description of violation and why prohibition isnecessary.

Each case is unique and must be considered on its own merits. There arehowever general principles that apply in the way each situation must beapproached. This document sets out the factors to be taken into account when


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considering the type of enforcement action to be taken. The policy must be

followed except in exceptional circumstances.The ZonesCorp EHS Specialists/Inspectors are authorised to take action, andare required to follow the policy and the lines of responsibility in terms ofdecision-making, as laid down in this documents. The decision and judgementof ZonesCorp EHS Specialists/Inspectors shall be considered final.

6.3 Baseline Environmental Incidents

In case of environmental the entity shall be required to undertakeenvironmental remediation as per the Emirate Environmental Protection Policy(EEPP) or the legal baseline. The legal baseline for the industrial cities shallbe the data submitted as a part of the Environmental Impact Assessment

Report.

All Incidents shall be reported to ZonesCorp in line with ZonesCorp Code ofPractice on Accident / Incident Reporting & Investigation (CoP-EHS05)

6.4 Penalties

Penalty or Citation or Fine shall be charged to an Entity for any non-compliance of EHS Laws / Regulations / EEPPs / Standards / Requirements ofZonesCorp Code of Practices etc. A list of ZonesCorp Code of Practices isgiven in Appendix 1 which is subject to change as deemed necessary byZonesCorp.

Penalty shall be payable over and above the cost of environmentalremediation or repair of damaged property or any legal compensation payableto affected parties / governmental agencies. Also the entity shall bear the costof investigation (not included in the penalty) like sampling, testing, analysis etc.

A base guideline for penalties, not including and over & above any legalcompensation payable is provided in Appendix 2. These are subjected tochange as and when deemed necessary by ZonesCorp.

Based on the Severity of Consequences the penalty value could increase fromthe minimum base guidelines as given in Appendix 2.The penalty would befixed by ZonesCorp EHS Specialist / Inspectors based on their professional

judgement and shall be final.6.5 Owners Responsibility

The EHS Specialist / Inspector's functions all relate to events in a place ofwork. In case of a transfer of facility ownership the new owner shall ensurethat the facility is totally EHS compliant and or may get himself indemnifiedfrom the non-compliant actions of the previous owner. However, allenforcement actions or legal proceedings shall be instituted against the currentowner and as per the prevalent UAE law and requirements of the concernedCompetent Authority.


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7 THE ENFORCEMENT PROCESS

The requirements of the EHS Law, regulations, ZonesCorp EHS Code ofPractices shall be taken into account during an EHS non-complianceinvestigation. The ZonesCorp EHS Manager is referred as the IndustrialSector EHS Regulatory Authority and shall ensure that fair and consistentdecisions are made about enforcement.

7.1 Enforcement Policy

7.1.1 Self Regulation by Entity No Action by Regulatory Authority

Self-regulation is a concept designed to enhance protection of human healthand the environment by encouraging the regulated community to voluntarilydiscover, disclose, correct, and prevent violations of relevant laws.

To participate in self-regulation the entity must be able to demonstrate thatthey:

a. Have identified, and know the implications to the entity of, all relevantenvironmental, health and safety legislation;

b. Provide for legal compliance with relevant legislation; and

c. Have procedures in place that enable the entity to meet these

requirements on an ongoing basis.Entities having established an EHSMS and are able to demonstrate selfregulation identifying EHS non-conformance themselves and reporting to theIndustrial Sector EHS Regulatory Authority along with a Corrective ActionPlan and Commitment Statement to ensure compliance at the shortestpossible practicable timeframe.

The Corrective Action Plan shall clearly identify the root cause for the non-compliance. The Corrective Action Plan and Commitment Statement shall besubject to acceptance as discussed in Section 7.2

However since the entity has identified and declared the EHS non-conformityin line with the principles of self regulation, enforcement of penalties shall bereviewed in accordance to the requirements of this CoP..

Also in the circumstance where compliance with legislation has been achievedor the expectation can be achieved by issuing a verbal warning, no actionwould be taken. However in case of verbal warning the entity shall submitcompliance report to ZonesCorp within the stipulated time. ZonesCorp EHSSpecialists / Inspectors shall physically verify the compliance based on theentity's report.


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7.1.2 Informal Action

Informal action to secure compliance with the legislation includes providingInformation issuing Warnings and Improvement Notice (format given inAppendix 1).

In the following circumstances it may be appropriate to use informal action.This is not an exhaustive list and each case must be looked at on its merits:

a. The activity or omission is not serious enough to warrant formal action.

b. From the Entitys past history it can be reasonably expected thatinformal action will achieve compliance.

c. Where the original approach is from person(s) seeking advice or

assistance (however, if serious breaches are found then formal actionwill be necessary).

When an informal approach is used to secure compliance, this may be verbalor written. However it is important that any written documentation issued orsent to individuals / businesses:-

a. Contains all the information necessary to understand what work isrequired and why it is necessary.

b. Indicates the statute or laws or regulations contravened and measureswhich will enable compliance to be achieved.

c. Clearly differentiates between legal requirements and recommendationsof good practice.

d. The stipulated time frame for the compliance of the contravened law orregulations.

7.1.3 Prohibition Notices, Equipment Seized or Closure of an Operation /Construction

Prohibition Notices shall be served to require offenders to cease contraveningactivities or seize the subject equipment, give offenders reasonable time torectify a contravention, or require entity owner/manager to provide information.

Prohibition Notices may require contravening activities to cease immediatelywhere circumstances relating to health, safety, environmental damage ornuisance demands and serious EHS Risks (format given in Appendix 1).

In other circumstances, the time allowed must be reasonable, but must alsotake into account the health, safety, environmental damage or nuisanceimplications of the contravention.

The circumstances under which Statutory notices shall be considered andserved, equipment seized or closure of a construction / operation would besuch that require immediate action otherwise could lead to seriousconsequences to Health & Safety of People or damage to Environment.


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7.1.4 Fixed Penalty for EHS Non-Compliance

Fixed Penalty Notices will be issued under specified legislation. If a fixedpenalty is not paid within the prescribed period, legal proceedings shall beinstituted. Even if the entity pays the fixed penalty but fails to comply with thelegal requirements, legal proceedings shall be instituted.

In case of environmental incidents over and above the fixed penalty, the entityshall bear the cost of environmental remediation as per the EEPP or the legalbaseline.

The structure of fixed penalties is given in Annexure -2.

7.1.5 Refusal / Revocation of EHS Licence / Permit

Licences, Approvals and Permits are issued under specific legislation and therequirements of the circumstances that allow refusal / revocation of licenceetc. shall be taken into account in accordance with the legislation.

In order to warrant refusal / revocation of an EHS Licence or Permit, the Entitymust meet one or more of the following criteria:

a. Engage in fraudulent activity (hiding an activity / undertaking anunauthorised activity / providing wrong or fabricated information)

b. Deliberately or persistently breach legal obligations (including therequirements of ZonesCorp EHS Code of Practice)

c. Deliberately or persistently ignore written warnings or formal notices

d. Endanger to a serious degree the health, safety or well being of people,flora & faunas or the environment

e. Failure to pay fixed penalty in case the entity fails to pay the fixedpenalty within the stipulated time frame

f. In cases of wider public interest, or if there is significant expenditureinvolved in compliance which jeopardises the financial viability of abusiness, reference may be made to the Licensing Authority.

7.1.6 Recommend Legal Action

In case an Entity that blatantly disregard the law, refuse to achieve even thebasic legal standards and / or who put the public at risk even after repeatedwarnings / disregard other enforcement actions like fixed penalty etc.ZonesCorp EHS Manager may recommend to the Concerned CompetentAuthority for legal action, which may include filing a legal case against theentity in the court of law. A recommendation for legal action would be made ifthe Entity falls under one of the following criteria:

a. Flagrant Breach of Law For example, where there is an apparentblatant breach of law such that public health, safety or well being, flora& fauna health or welfare is put at serious risk, it would be appropriateto recommend legal action.


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b. Failure to Comply with a Prohibition Notice legal action may be

recommended in cases of failure to comply with improvement notices orother notices requiring actions to ensure compliance.

c. Failure to Pay Fixed Penalty legal action may be recommended incases of failure to pay fixed penalty and also fulfil required improvementactions to ensure compliance.

d. Failure to Comply with Lawful Requirements If the operator of anEntity fails to comply with lawful requirements, having been advised onprevious occasion(s), legal action shall be recommended.

e. History of Non-compliance If there is a history of non-compliancewith law by the operator of a business or by an individual then legal

action shall be recommended even if the matters identified are notflagrant breaches of law.

f. Community Benefit Legal action shall be recommended on the firstoccasion that certain events are witnessed because of the extremeimprobability that the person once seen committing an offence would beseen on a subsequent occasion. Community benefit of a legal actionwould also be indicated by the importance of the case, for example,whether it might establish a legal precedent.

g. Obstruction Legal action shall be recommended in cases ofdeliberate obstruction of a ZonesCorp EHS Specialist/Inspector.

7.2 Corrective Action Plan

In case an EHS non-conformity is identified whether by the entity themselvesor by the Industrial Sector EHS Regulatory Authority or a third party externalauditor, the entity shall be required to develop within 15 calendar days, aCorrective Action Plan and Commitment Statement to ensure compliance atthe shortest possible practicable timeframe and submit the same to IndustrialSector EHS Regulatory Authority. The Corrective Action Plan shall clearlyidentify the root cause for the non-compliance, immediate action taken and thetime frame for closing the non-compliance.

The Corrective Action Plan and Commitment Statement shall be reviewed bythe Industrial Sector EHS Regulatory Authority and depending upon theseverity of the consequences, the same may be accepted or may advice theentity to cease contravening activities or seize the subject equipment until thecorrective action has been implemented and compliance has been achieved.

On receipt of the conformity report submitted by the entity, the IndustrialSector EHS Regulatory Authority shall physically verify the compliance on siteif the need be through a process of environmental assessment and close outthe non-conformity.


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7.3 Shared Enforcement Role

Before proceeding with any action ZonesCorp EHS Specialists / inspectorsshall consider if there is a shared or complementary enforcement role withother agencies e.g. Civil Defence, Environment Agency Municipality, ADWEAetc. and liaise with such agency.

7.4 Power of EHS Specialist / Inspectors

EHS Specialists / Inspectors may enter a place of work / Entity's premises forthe purpose of carrying out any of the functions

A visiting EHS Specialist / Inspector is not required to give advance notice,

except where the visiting time or circumstances may be other than what is"reasonable" in the circumstances.

Access shall therefore be available to any place of work during its regularworking hours (including all shifts), and where there are not othercircumstances which would make the timing of the visit unreasonable.

The EHS Specialist / Inspector may:

a. Conduct investigation including examinations, tests, inquiries interviewan employee and inspections or direct others to conduct them; and/or

b. Seek information, data, records, procedures to satisfy themselves that

the activities are in compliance with the EHS Laws and regulations;and/or

c. Record statement, take photographs or measurements, or makesketches or recordings

The EHS Specialist / Inspector may also require the employer or other personwho controls the place of work:

a. Not to disturb the place of work for a reasonable period while anyexamination, test, inquiry or inspection is carried out; and/or

b. To produce documents or information relating to the place of work or

the employees who work there, and permit the inspector to make copiesof or extracts from them; and/or

c. To make or provide statements in a specified form or manner aboutconditions, material, or equipment that affects the safety or health ofemployees who work there or harm to environment.

To carry out these functions, the EHS Specialist / Inspector may beaccompanied and assisted by other people, or bring any necessary equipmentinto the place of work.

7.4.1 An EHS Specialist / Inspector is authorised to require a duty holder or anyother person that controls a place of work to make or provide statementsabout:


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a. Conditions;

b. Material; or

c. Equipment,

That affects the environment, health or safety of employees.

Such statements may be made in the course of routine inspections, or whilethe EHS Specialist / Inspector is investigating an accident or incident.

The statements may be written, oral, or in any other form or manner specifiedby the EHS Specialist / Inspector. The inspector's requirement of statements isin addition to the powers to require documents or other information as set outabove.

A statement provided to an EHS Specialist / Inspector under the provision ofthis Code of Practice, or documents or other information provided to the EHSSpecialist / Inspector, may form the basis of enforcement notices issued by theEHS Specialist / Inspector, or may be used in evidence in any subsequentcourt proceedings.

7.5 Authorisation Of Documents

Individuals authorised to sign various documents (Improvement Notice /Prohibition Notice / Fixed Penalty / Revocation of EHS Permit etc.) on behalfof the Industrial Sector Regulatory Authority shall, in general, have the level of

experience and responsibility of the post as referred to in their job descriptionsand specifications and outlined in the scheme of delegations and associateddocuments.

EHS Specialist / Inspector shall sign and issue Improvement Notice /Prohibition Notice / Fixed Penalty and shall obtain approval of ZonesCorp EHSManager for Refusal / Revocation of EHS Licence / Permit.


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8 REFERENCES

8.1 ZonesCorp Code of Practice on EHS Management Framework (CoP-EHS01)

8.2 ZonesCorp Code of Practice on EHS Management System (CoP-EHS02)

8.3 ZonesCorp EHS CoP on EHS Impact Assessment (CoP-EHS04)

8.4 ZonesCorp EHS CoP on EHS Incident Reporting & Investigation (CoP-EHS05)

8.5 ZonesCorp EHS CoP on EHS Performance Monitoring & Reporting (CoP-EHS06)

8.6 ZonesCorp EHS CoP on EHS Compliance Assurance (CoP-EHS11)

8.7 ZonesCorp Code of Practice on Waste Management (CoP-E03)

8.8 ZonesCorp Code of Practice on Crisis Management Plan (CoP-FE05)

8.9 ZonesCorp Building Control Unit Technical Handbook

8.10 EAD EHSMS Volume 2 Section 2 Quality Indicators And Standards


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APPENDIX 1

EHS REGULATORY FRAMEWORK CODES OF PRACTICE &GUIDELINES FOR INDUSTRIAL SECTOR (Partial List)

Sr. No. Code of Practice & Guidelines Document No.

Environment Health & Safety (EHS)

1 EHS Management System (EHSMS) Framework CoP-EHS01

2 EHS Management System CoP-EHS02

3 EHS Risk Management CoP-EHS03

4 EHS Impact Assessment (EHSIA) CoP-EHS04

5 EHS Accident/Incident Reporting & Investigation CoP-EHS05

6 EHS Performance Monitoring & Reporting CoP-EHS06

7 EHS Management of Industrial Cities CoP-EHS07

8 EHS Management of Workers Residential Cities CoP-EHS08

9 EHS Management of Projects CoP-EHS09

10 Integrity Assurance & Management CoP-EHS10

11 EHS Audits & Inspections CoP-EHS11

12 EHS Compliances Enforcement CoP-EHS12

13 EHS Training & Awareness CoP-EHS13

Environment

1 Construction Environment Management Plan (CEMP) CoP-E01

2 Operations Environment Management Plan (OEMP) CoP-E02

3 Waste Management CoP-E03

4 Pollution Prevention & Environmental Compliance Assurance CoP-E04Health

1 Occupational Health Surveillance and Monitoring CoP-H01

2 Occupational Health Welfare Management CoP-H02

3 Food Safety Standards CoP-H03

Safety

1 Construction EHS Management Plan (CEHSMP) CoP-S01

2 Operation Health & Safety Management Plan (OHSMP) CoP-S02

3 Transport Management Plan (TMP) CoP-S03


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Sr. No. Code of Practice & Guidelines Document No.

4 Contractors Safety Requirements CoP-S04

Fire & Emergency

1 Fire Risk Management (FRM) CoP-FE01

2 Fire Protection System Design Criteria CoP-FE02

3 Emergency Response Plan (ERP) CoP-FE03

4 Emergency Communication CoP-FE04

5 Crisis Management Plan (CMP) CoP-FE05

6 Incident Command System (ICS) CoP-FE06Code of Practices Guidelines

5 EHS Manual for Workers Residential Cities CoP-GL05

Note: This list of CoPs and Guidelines is not final, additional Code of Practices will bedeveloped as deemed necessary by ZonesCorp and communicated to all concerned.


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APPENDIX 2

PENALTIES FOR EHS VIOLATION

Note: These are base guidelines for penalties not including and over & above any legal compensation

payable. These are subjected to change as and when deemed necessary by ZonesCorp

NO. TYPE OF VIOLATION PENALTYZC COP

REFERENCE

1Failure to establish or non-compliance to Substance AbusePolicy

A minimum fine of AED 5,000EHS01

EHS02

2.Failure to establish, maintain andimplement the Training Programincluding both the Craft and EHS

A minimum fine of AED 5,000EHS01

EHS02

3Start Construction or Operationprior to obtaining the appropriateEHS Permits

Stop activity, obtain the desiredpermit and a minimum fine ofAED 25,000

EHS07,EHS08, E01,E02, S01, S02

4

Failure to have theenvironmental analysisperformed by an approved

environmental laboratory at thetime environmental study beingundertaken.

Rejection of the analysis results,requiring that the analysis beredone by an approved

environmental laboratory and afine ranging between AED 3,000to 5,000

EHS04

5Incorrect analysis results orcomponents of environmentalstudy

Resubmit the study andimposition of a fine of AED 5,000to AED 10,000 on the violator

EHS04

6.

Failure to comply with theundertakings, conditions andspecifications listed in the EHSstudies to obtain the EHS Permit

A fine of AED 10,000 to 50,000

EHS04,EHS07,EHS08, E01,E02

7

Failure to submit the Monthly /Periodic Reports in accordancewith the EHS PerformanceReports / Construction EHSManagement Plan / OperationEHS Management Plan andEHS Permit conditions within thestipulated time frame (within 7working days of the last date)

Submit the appropriate Reportwithin 7 Working days

Suspension or refusal of renewalof the EHS Permit granted andimposition of a fine up to AED5,000

EHS04,EHS05,EHS06,EHS11,EHS07,EHS08, E01,E02, E03, E04,S01, S02

8

Failure to conserve biodiversity

including killing of a rare speciesor cutting of tree

Recommendation for legal action(proceedings) EHS04, E01


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REFERENCE

9Failure to apply for renewal ofthe EHS Permits one monthsahead of its expiration date

Denial of renewal and or a fine ofminimum AED 5,000 pendingrenewal of the EHS Permit

EHS07,EHS08, E01,E02, S01, S02

10

Failure to produce, maintain or

implement Waste ManagementPlan

A minimum fine of AED 10,000 E03, E04

11Disposal of untreated / partiallytreated sanitary wastewater inmarine environment


12Disposal of untreated/ partiallytreated sanitary wastewater onland


13

Discharge (injection) ofuntreated/ partially treatedsanitary wastewater into groundwater bodies


14

Discharge of treated sanitary /trade wastewater that does notconfirm to environmentalstandards and criteria


15

Discharge (injection) of treatedsanitary / trade wastewater thatdoes not confirm to

environmental standards andcontaminate ground water


16 Disposal of sludge in the sea A minimum fine of AED 7,000 E03, E04

17Disposal of sludge into waterbodies other than marineenvironment


18Disposal of sludge in areas thatare not designated for it


19Unauthorized Storage of Material

(outside entitys premises).

A minimum fine of AED 5,000E01, E02, E03,

E04


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REFERENCE

20Violations involving samplecollection procedures that areinconsistent with the criteria.

A minimum fine of AED 3,000 EHS04

21

Violations involving measurement

and analysis procedures that areinconsistent with the criteria


22Pollution/contamination of groundor surface water with hazardousor toxic (harmful) substances

Remediation and a fine up toAED 500,000 (1/2 MillionDirhams)

E01, E02, E04

23

Pollution / contamination ofunderground or surface waterwith high concentrations of non-hazardous pollutants

Remediation and a fine up toAED 250,000 (1/4 MillionDirhams)

E01, E02, E04

24Failure to comply with theemission monitoring program A minimum fine of AED 10,000 E01, E02, E04

25Tampering with monitoring andobservation devices

A minimum fine of AED 15,000 E01, E02, E04

26Release of pollutants withoutadvance notice


27Failure to report facilityshutdowns resulting in pollutantsgas emissions


28 Neglect the maintenance of pollutionabatement and surveillance &monitoring equipment

A fine of AED 10,000 to 30,000 E01, E02, E04

29

Failure to operate pollutionabatement, monitoring andsurveillance equipment to therequired efficiency


30

Failure to comply with theprocedures related to thehandling of emissions and leaks

in cases of emergency



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REFERENCE

31Open burning of domesticconstruction wastes

A minimum fine of AED 10,000 E03

32

Failure to establish or Non-compliance to Environment

Compliance Assurance Plan(ECAP)


33Non-compliance to PollutionPrevention and Control Plan


34Failure to segregate andproperly store Hazardous Waste


35

Failure to manage waste as perthe Waste Management Planincluding failure to maintain /produce proper manifestations

A fine ranging from AED 5,000 to10,000

E03

36Unauthorised waste / liquidwaste disposal on land or inmarine environment


37

Unauthorised waste / liquidwaste disposal within thepremises of industrial cities ofAbu Dhabi Emirate


38

Unauthorised use of scrap orwaste as raw material for

manufacturing packaging or anyother purpose

A fine of AED 10,000 to 30,000

EHS07, E02,

E03, S02

39Violations by the licensee of thehazardous waste storageconditions and specifications

Fine from AED10,000 to 25,000and EHS Permit cancellation

E03

40

Failure to pack hazardous wastesin appropriate shockproof and antispill and anti-evaporation/sublimation containers

Fine from AED 5,000 to 10,000and EHS Permit cancellation

E03

41 Failure to place conspicuouslabels on storage vessels,

Fine from AED 5,000 to AED10,000, requiring the violator to

E01, E02, E03,E04, S01, S02


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REFERENCE

including the type and hazardrating, characteristics and UNnumber of the stored material

repack the material inaccordance with thespecifications and licensecancellation warning

42

Transportation of hazardouswastes to the waste collectionfacility using a means oftransportation not authorized bythe Competent (EAD) / RegulatoryAuthority (ZonesCorp)

Fine from AED 10,000 to AED20,000 and EHS Permitcancellation

E03, S03

43

Transportation of hazardouswastes with incompatiblecharacteristics and qualities tothe hazardous wastemanagement facility in one or

the same means oftransportation


E03, S03

44

Transport of hazardous wastesto an agency or facility notauthorized by the Competent /Regulatory Authority


E03

45Failure to carry the manifest ofthe wastes being transported

Fine from AED 10,000 to AED20,000 & EHS Permit cancellation

E03

46

Excessive noise pollution from

vehicles or Plant / Machinery orConstruction/Operation activity

A minimum fine of AED 5,000E01, E02, E04,S01, S02

47Excavations and constructionworks outside designated hours

A minimum fine of AED 5,000EHS09, E01,S01, S02

48

Failure to fence off excavationsresulting from constructionactivities or failure to maintainthem regularly, thereby exposingpassers by to hazards

Rectify the maintenance of thefence and excavations.Imposition of a fine of AED 5000to 10000

EHS09, E01,S01, S02

49 Use of un-inspected or faultyscaffolding A minimum fine of AED 10,000 EHS09, S01,S02


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REFERENCE

50Failure to provide safe workenvironment including poorhousekeeping


S01, S02

51 Failure to display/provide MSDS A minimum fine of AED 2,000E02, E04, S01,

S02, H01

52Personal Protective Equipment(PPE) non-compliance bypersonnel

A minimum fine of AED 1,000 H01, S01, S02

53Failure to provide PPE as per jobrequirement

A minimum fine of AED 5,000 H01, S01, S02

54

Failure to undertake riskassessment and comply to safeworking procedures includingPermit To Work etc.

A minimum fine of AED 5,000

EHS03,EHS04,EHS09, S01,S02

55Failure to store Gas cylindersproperly including proximitydistances & compatibility issues

A minimum fine of AED 5,000EHS09, S01,S02

56Storage of incompatiblehazardous substances

A minimum fine of AED 5,000E01, E02, S01,S02

57

Failure to provide adequate FirstAid & Emergency Equipment likeEye Wash, Emergency Shower,Spill Response Kit etc.

A minimum fine of AED 5,000EHS09, E01,E02, E04, S01,S02, H01, H02

58Failure to undertake regularworkplace monitoring

A minimum fine of AED 5,000 EHS06, H01

59Failure to conduct and maintainoccupation health monitoringrecords

A minimum fine of AED 10,000 EHS06, H01

60Failure to get lifting equipments& tools inspected by approved3rdParty

A minimum fine of AED 5,000S01, S02,EHS09,EHS10

61

Use of plants, machines, lifting

equipments & tools NOT A minimum fine of AED 10,000

S01, S02,

EHS09,


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REFERENCE

inspected by approved 3rdParty EHS10

62Failure to get pressure vesselsetc. inspected by approved 3rdParty


63Conducting heavy liftingoperation without the presenceof a Competent Rigger


64Failure to establish ERP or displayemergency contact numbers,mark emergency exits etc.

Submit the ERP approved byCivil Defence within 15 workingdays and a minimum fine of AED10,000

EHS07, FE03

65Failure to train all concerned onERP and undertake drills as perplan

A minimum fine of AED 5,000 EHS07, FE03

66Failure to report incidents toIndustrial Sector RegulatoryAuthority

A minimum fine of AED 5,000EHS05,EHS06

67

Endangering human life byengaging personnel withoutproper craft training or experienceto hazardous activities

A minimum fine of AED 10,000EHS01,EHS02,EHS03

68

Sheared Enforcement:Unauthorized Operation of a

facility that the concernedagency has ordered to shutdown or eliminate and withoutapproval of the Industrial SectorRegulatory Authority

A fine from AED 30,000 to50,000 and closure of the facility.Also recommend legalproceedings.

EHS04,EHS07,EHS12, E01,E02, S01, S02

69

Failure to comply to and provideWelfare facilities as per therequirements of ZC CoP H02in the industrial and workerresidential facilities


H02, EHS08

70 Failure to comply with(exceeding) the maximum

A minimum fine of AED 5,000 H02


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REFERENCE

occupancy number in a room inworker residential cities / labourcamps as per the ZonesCorprequirements

71 Failure to submit 3rdParty Audit

reportSubmit 3

rd

Party Audit Reportwithin 15 calendar days and aminimum fine of AED 5,000

EHS06,EHS11, E01,E02, S01, S02

72Failure to comply to ProhibitionNotice

EHS Permit cancellation, closureof the total operation /construction and a fine of AED50,000

EHS12

73Failure to submit CorrectiveAction Plan within 15 calendardays


EHS12

74Failure to develop, maintain orimplement the TransportManagement Plan (TMP)

Submit the TMP within 15working days and a minimumfine of AED 5,000

S03

75Failure to develop, maintain orimplement Fire RiskManagement Plan (FRSP)

Submit the FRSP approved byCivil Defence within 15 workingdays and a minimum fine of AED20,000

FE01, FE02

76For Construction Worksites:Failure to develop and maintainthe EHS Manual

Develop EHS Manual within 7days and a minimum fine of AED10,000

S01

77For Operating Worksites:Failure to develop and maintainthe O&M Manual or EHS Manual

Develop O&M and EHS Manualwithin 15 days and a minimumfine of AED 10,000

S02

78Failure to establish or implementContractor EHS ManagementPlan

Develop and ImplementContractor EHS ManagementPlan within 7 days and aminimum fine of AED 10,000

EHS09, S01

79Failure to provide theappropriate Safety/Hazard

Warning Signs and Instructions

Install the appropriate signs /instructions and a minimum fine

of AED 5000

EHS09, S01,

S02, S04


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REFERENCE

80

Workplace violations leading toInjuries and/or other EHSIncidents including PropertyDamage

A minimum fine of AED 10,000EHS03,EHS05, H02,S02

81Barring EHS Specialist /Inspector from inspection ofpremises / operations (1stoccasion)


82

Barring EHS Specialist /Inspector from inspection ofpremises / operations (2ndoccasion)


83 Security BreachesAs listed in ZonesCorp CoP onSecurity Access Control

SEC01


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CODE OF PRACTICE


APPENDIX 3

EHS ENFORCEMENT NOTICEINDUSTRIAL SECTOR REGULATORY AUTHORITY

IN THE EMIRATE OF ABU DHABI

Date of Inspection:

IMPROVEMENT NOTICE PROHIBITION NOTICE PENALTY NOTICE

NOTICE ISSUED TO:

Company Name

Address

Location(Specific details ofconstruction / operation area)

ISSUES REQUIRING ACTION:

Regulations, COP Description of Contravention / Non-Compliance Penalty

ACTION: May Include but not limited to:

Closure of Operation / Prohibition for Use of / Seizure of Equipment / /.

Develop / Obtain & Submit OEHSMP / CEHSMP / WMP / ECAP / PP&CP / FRMP /ERP / TMP / Inspection Certificates / EHS Permit / O&M Manual / EHS Manual etc.Others:.

Submit: Action Plan / Enforcement Statementby (date).

The notice is to be complied with on or before

NOTICE ISSUED BY:The enforcement notice is being enforced by ZonesCorp EHSSpecialist / Inspectors based on their best professional judgement and shall be final.

Name:

Designation:

Signature:

Date : Time: