IMS REPORT 2021
MANAGEMENT REVIEW OF THE ENVIRONMENT-SAFETY MANAGEMENT SYSTEM YEARS 2021-2022
This review takes into account the input data for the year 2021, which provides considerations and potential for improvement for the year 2022.
On 17-25-26/03 and 1/04/2021, the second surveillance audit for the Safety Management System was carried out by Dekra (see report I-K-1018518 dated 1/04/2021).
The environment and safety audits, scheduled in the reporting period, were regularly carried out in 2021, as were the monthly environment-safety tours.
A few non-conformities emerged, which were handled in the procedural manner and will be examined in detail in the following points.
The highest percentage of NCs is due to incorrect waste management, general untidiness and fire extinguishers that are either not accessible or incorrectly numbered; next comes the problem of chemicals that are not correctly identified or the SDSs are lacking.
STATISTICS ON NON-CONFORMITIES (ACCIDENTS AND INJURIES FOR SGS)
A total of 5 non-conformities and 34 observations emerged from internal audits.
Some recommendations were reported from the Certifier's audit, which the company is working on as a basis for improvement.
Four accidents occurred during the year 2021 (one was actually classified as a disease), only one required action, which was managed accordingly by generating a RAC, and was classified as non-conformities.
The other two were classified as accidental events and, therefore, did not require any action.
In addition, 5 near-misses were reported and managed in accordance with the procedure.
Two corrective actions were required to address the non-conformities identified during the audits.
These actions are detailed in the relevant documents.
The first action, initiated on 27/04/2021, following the NEAR MISS 2, entailed some changes to the electrical system of the shaving chains, which were carried out in August.
The second action, initiated on 24/11/2021, following NC 5 – injury involving a temporary employee in the MTG CIL department – where it is mandatory to provide operators with safety goggles and affix the warning of ALWAYS wear them during blowing operations. This requirement has been fulfilled.
The efficacy of this action was verified during the periodic inspections (namely Tour 9), noting that the operators were equipped with their goggles and wore them during blowing operations.
In addition, the Dekra audit identified a minor Non-Conformity, which was immediately followed by a major corrective action, which involved fixing the paperwork regarding in-house machines by the end of April 2022.
OPPORTUNITIES FOR IMPROVEMENT
The Dekra audit revealed 14 opportunities for improvement which the company has taken into consideration and completed, except for No. 12, which is scheduled for completion in September 2022.
OBJECTIVE ACHIEVEMENT STATUS
Four improvement projects were planned for 2021:
- Company car fleet made up of at least 50% electric or hybrid cars: the timeframe of the project is 5 years – as of 31/12 electric or hybrid cars accounted for 5%.
- Installation of department entrance doors with double interspace to minimize heat loss: 2 doors installed, one in the washing area (on the compressors side) and one in the shipping area (outside the facility).
- Weight setters for the shipping department: already purchased, they will be installed by the end of January 2022.
- Specific action to reduce MMC on all workstations: activities have been carried out in the MTG CIL department (see specific documentation by SPP); action will continue in 2022 in the via Borsellino shipping and tumbling departments.
TRAINING AND COMMUNICATION
Initial in-house training was provided in 2021 for new recruits, covering both safety and environmental issues.
Compulsory safety training was provided for new recruits and refreshing courses have been provided for workers.
Only part one of this training was carried out, due to the limitations imposed in the early part of the year by Lombardy's entry into the reinforced orange zone; the second part will be provided by June 2022.
PARTICIPATION AND CONSULTATION (SAFETY) – including OUTPUTS FROM RLS MEETINGSA meeting of the Prevention and Protection Service was held on 15/01/2021. A presentation was made regarding the status of reviews of DVR chapters, the trend in accidents-occupational diseases and health surveillance, PPE and the relevant choice criteria and the training programme.
Two RLS Consultation meetings were also held:
- RLS consultation for environmental surveys 2021, held on 8/11/2021 and 14/01/2021.
- RLS Consultation for CYLINDER ASSEMBLY biomechanical overload, held on 08/04/2021
The documentation relating on these meetings is kept on file by SPP.
On the legislative side, Metal Work has taken note of the release of new statutory requirements and has modified, where appropriate, its operations and procedures.
The main stakeholders issuing any communications or requirements have been identified:
Regional Environmental Agency (ARPA)
Fire Brigade (VVFF)
Municipalities (including neighbourhood)
Health Protection Agency (ATS)
ENVIRONMENTAL PERFORMANCE DATA AND INDICATORS
All data and indicators in this section cover the whole of 2021.
No. of infringements=0; no. of accidents=0; limits exceeded on total analyses performed: none; no. of complaints/reports from stakeholders= 0.
The indicators identified as significant are shown in the attached graphs.
COMMENTS ON DATA
Considerations on resource consumption, hazardous substances, packaging, waste generated, atmospheric emissions, water drains, soil and subsoil contamination, noise, landscape and visual impact are reported in the annual environmental review upgrade.
CHANGES IN SURROUNDING SITUATIONS AND LEGAL REQUIREMENTS
Metal Work has taken into account:
- EU Regulation 2020/878 of 18/06/2020: amendment to Annex II of EC Regulation 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH): Safety Data Sheets not conforming to the Annex of this Regulation can continue to be supplied until 31 December 2022. The company plans to bring forward the request to update the Safety Data Sheets of substances in use to June 2022, in order to be compliant for the legal deadlines.
- Law Decree 228 of 30 December 2021: extension until 30 June 2022 of the implementation of the mandatory environmental labelling for all packaging put on the market in Italy, pursuant to article 219, paragraph 5 of Legislative Decree 152/2006: Packaging that does not meet the requirements envisaged therein, has already been put on the market or labelled by 1 July 2022, may be marketed until stocks are depleted.
- Law Decree 77 of 31 may, converted into law no. 108 of July 2021: the responsibility for the correct disposal of waste in the case of sending operations identified as D13, D14 and D15 does not lie with the manufacturers (no longer necessary to receive the certificate of disposal from the waste recipient).
- Directorate Decree no. 47 of 9 August 2021: the Waste Classification Guidelines set out in Resolution no. 105 of 18 May 2021 of the National System Council for Environmental Protection, as supplemented by subsection entitled “3.5.9 – Waste generated by the mechanical/mechanical-biological treatment of unsorted town waste”: in the coming month, the company will classify its waste in accordance with these provisions.
Decree-Law no. 1 of 5 January 2021
Prime Minister’s decree of 14 January 2021
Decree-Law no. 12 of February 2021
Decree-Law no. 15 of 23 February 2021
Lombardy Government’s order no. 750 of 23 February 2021
Lombardy Government’s order no. 714 of 4 March 2021
Prime Minister’s decree of 2 March 2021
Decree-Law no. 44 of 1 April 2021
Ministry of Health’s circular no. 0015127 of 12 April 2021
Shared protocol for updating measures to contrast and mitigate the spread of SARS-CoV-2/COVID-19 in the working environment
Decree-Law no. 52 of 22 April 2021
Decree-Law no. 65 of 18 May 2021: urgent measures related to the epidemiological emergency from COVID-19
Ministry of Health’s circular of22/06/2021
Decree-Law no. 105 of 23 July 2021
Ministry of Health Communication of 11 August 2021
Decree-Law of 21 September 2021
Decree-Law no. 139 of 8 October 2021
Prime Minister’s decree of 5 October 2021 and 12 October 2021 and Circular of the Ministry of Infrastructure and the Ministry of Health of 14 October 2021
Text of Decree-Law no. 127 of 21 October 2021, coordinated with conversion law no. 165 of 19 November 2021
Decree-Law no. 172 of 26 November 2021
Prime minister’s decree of 17 December 2021
Decree-Law no. 221 of 24 December 2021
Decree-Law no. 229 of 30 December 2021
OTHER REFERENCE REQUIREMENTS
- Ministerial Decree of 11 February 2021: Implementation of European Parliament and Council Directives EU 2019/130 of 16 January 2019 and EU 2019/983 of 5 June 2019 amending European Parliament and Council Directive EC 2004/37 of 29 April 2004 on the protection of workers from risks relating to exposure to carcinogens or mutagens at work. The company pursues the assessment of risks associated with exposure to carcinogens or mutagens in light of the changes made to Annexes XLII and XLIII.
- Inter-ministerial Decree of 18 May 2021: Implementation of Commission Directive 2019/1831/EU of 24 October 2019, which establishes a fifth list of indicative occupational exposure limit values, by implementing Council Directive 98/24/EC and amending Commission Directive 200/39/EC.
- Decree-Law no. 146 of 21 October 2021: urgent measures on economic and fiscal matters, to protect labour and for non-deferrable needs.
- Text of Decree-Law no. 146 of 21 October 2021, (published in the Official Gazette no. 252 of 21 October 2021) coordinated with conversion law n. 215 of 17 December 2021 (in this same Official Gazette at page 1) containing: "Urgent measures on economic and fiscal issues, to protect labour and for non-deferrable needs": the company considers the need for formal appointment of supervisors and news on the training of the DdL and the updating of supervisors, managers and DdL at least every two years, when the Permanent State-Regions Conference will have decided.
SIGNIFICANCE OF ENVIRONMENTAL ISSUES
The initially identified environmental issues are considered still valid with the changes specified below.
In 2015 the assembly departments were moved from Via Segni to the new premises in Via Borsellino. No environmental issues have been added, however.
An initial environmental analysis of the Via Borsellino premises was carried out in early 2016.
During 2016, the transfer of the assembly departments to the new Via Borsellino premises resulted in a change in the location of air emission points.
The environmental issues have not changed, however, because the emissions concern substances that already existed in the company before they were authorised.
As of 9 January 2017, a canteen service, provided by a catering company, is in place. However, this does not add any environmental issues: there is merely an increase in the amount of waste disposed of, as well as in the type (glass and organic fraction).
In 2017, no changes occurred in processes that led to additions/changes in environmental issues and their significance.
In 2018, the METAL WORK PRODUCT LIFECYCLE ANALYSIS datasheet (point 2A, with significance 1) was merely added; an activity formalized following the transition to the ISO 14001:2015.
In June 2019, the emission point E10 was modified (6 new machines for mechanical processing have been installed, which entailed the upgrading of the extraction system and the replacement of the existing stack with one with a larger diameter due to increased flow rate); the relevant analyses were carried out in September 2019.
In 2020, a digital tomography system was introduced, making it possible to carry out measurements and X-ray scanning; the system was evaluated from a health and safety point of view, but it does not involve any environmental issues.
In 2021, measurements for the presence of radon gas have been carried out in selected areas of the company; these measurements will be completed by June 2022.
No environmental issues were added or changed during 2021.
Given the process of adapting the Environmental Management System to the 2015 revision of the ISO 14001 standard, a new Policy was issued in October 2017.
During 2018, a new revision of the Policy was issued with the desire to adapt the Occupational Health and Safety Management System to the UNI ISO 45001 standard.
This contains all of the Management's commitments expressed in the previous policy, to which the issues related to the new standard have been added.
It is considered still valid.
This was documented in the report "Context analysis, stakeholders and their expectations" of November 2018 rev.2; compared to the previous one, the part relating to health and safety issues was added, following the introduction of ISO 45001:2018.
This was updated in January 2021, including of course the new data and numbers for the markets and a description of the situation following the Covid-19 pandemic.
The section on environmental and operational risks is managed using the already existing analysis of environmental aspects and assessment of their significance; management risks have been assessed and formalised in the "Risks of management processes" matrix, as updated on 7 January 2021
(Common assessment matrix for all management systems)
As mentioned above, occupational health and safety-related risks are clearly dealt with in the DVR; a risk matrix of management processes has been formalised, as mentioned above.
VALIDITY AND EFFECTIVENESS OF DOCUMENTATION
During the year 2018, part of the documentation of the safety management system was reconsidered, as efforts were made to comply with UNI ISO 45001:2018.
Some documents were modified, such as the Policy, “Analysis of the context, stakeholders and their expectations” and the “Analysis of management process risks related to environment/safety”.
The Management System Manual was amended accordingly.
No substantial changes to the documentation were required in the course of 2021; some procedures (with the corresponding documentation) concerning the introduction of substances and machines were updated.
No substantial changes to the documentation were needed in the course of 2021; some procedures (with the corresponding documentation) concerning the introduction of substances and machines were updated.
The scope is the same and is considered still valid. The only difference was the addition of the Via Borsellino production site in 2016.
The standard product lifecycle, which was formalized in July 2017, is considered still valid; additional detail was added on 07/01/2021 regarding the process steps, from sale to customer through to installation, use and final disposal, as well as in-house production and assembly.
At the end of 2019, the company's CODE OF ETHICS was drawn up and published on the company website.
IMPROVEMENT PROJECTS FOR THE YEAR 2022
- Vehicle fleet consisting of at least 50% electric or hybrid cars – ongoing since 2021 and bound to continue for 5 years.
- Heating system for former Tecnopolimeri building (heat pumps instead of natural gas).
- Air extraction system project for former Tecnopolimeri building.
- Lifelines on MCM machines.
- Loading equipment for the deburring and shipping areas at Via Borsellino premises (to reduce the MMC value) – an ongoing project since 2021.
- Extraction system in the valve laser area.
Waste sent to regeneration and to discharge