design ems for pharma labs
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2011
Environmental Management
System- Pharma LABS LTD.(Pharmaceutical & Food Analysis)
Submitted By:-
Eshan Gupta (1065)
Gautam Kr Gulshan (1066)
Sampath Gelam (1082)Sandeep Goel (1083)
Shubham Kumar (1086)
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1. About the OrganisationXYZ is a contract testing and analysis laboratory based in ABC, India. We analyze, for our clients, or as a
regulatory requirement, pharmaceuticals, food and agricultural products, construction materials, chemicals
etc. We also help industries in their research processes. Our environment consultancy division helps firms in
keeping the environment clean and free from pollution.
As an independent drug analysis it does not just help pharmaceutical companies to release the drug to the
market and meet FDA norms - it also helps save lives. As a food products' analysis provider, it provides
valuable source of data to government bodies in preventing adulteration - it also helps create consumer
awareness. For example analysis of Cement and Building materials not only helps the civil engineers in
building new structures - it helps a nation to develop its infrastructure. Similarly, XYZ design Industrial
Effluent Systems, and they are not just helping industries to meet PCB norms - they help make tomorrow a
more livable place.
2. Environmental Policy
1. Complianceo We will comply with all applicable environmental laws and regulations.o We will implement programmes and procedures to assure compliance.o Where existing laws and regulations are not adequate to ensure protection of the
environment, we will establish and meet our own environmental quality standards.
2. Preventiono We will implement management systems and procedures designed to prevent activities and /
or conditions that pose a threat to the environment.
o We will strive to prevent release of harmful pollutants to the atmosphere, land or water.o We will minimize the amount and toxicity of waste generated and ensure the safe treatment
and disposal of waste.
3. Continual Improvemento We will continually seek opportunities to improve our adherence to these principles, and will
periodically report progress to our clients in the Laboratory's annual report.
4. Communicationo We will communicate in the Laboratory's annual report our commitment to environmental
quality to our staff and clients.
o We will solicit their input in meeting our environmental goals and in turn offer assistance tomeet their goals.
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3. Environmental Aspects3.1 Environmental impacts and risks
The major environmental impacts from processes carried out by the pharmaceutical industry stemfrom the use of solvents as reaction media and as aids for separation and purification processes.
The solvents may be emitted directly into the atmosphere as VOCs (Volatile Organic Compounds),
or may appear in wastewater. Sources of the latter include solvent residues from separative
operations involving both water and solvent phase, as well as solvents captured in wet scrubbers.
A secondary impact from pharmaceutical operations is dusts generated by grinding and polishingoperations
3.2Various Environmental AspectsSome of the environmental impacts associated with regular laboratory operations are listed below:
Water Pollution
The food and drug laboratories use a wide range of chemicals, disinfectants and sample drugs.
Direct release, without treatment and segregation of any of these chemicals and hazardous wastes to
the drain without treatment can contaminate and corrode the waste water system and create health
risks for the general public, directly or indirectly. Such pollution is also detrimental to aquatic life
and the marine environment.
Air Pollution
The operation of laboratories may result in a number of hazardous emissions to the air from fume
hoods and vents, sterilization / disinfection technologies; plant operations (boilers and generators),
refrigerants (Ozone depleting substances) and treatment technologies (incinerators, if any). Open and
incomplete burning of wastes can create hazardous air emissions such as dioxins
Soil Contamination
The disposal of untreated and un-segregated solid waste (containing organic, degradable mixed
with hazardous chemicals) can result in contamination of the soil and the solid waste system.
Handling & Disposal of Chemicals and hazardous wastes
Improper handling of hazardous chemicals is a health hazard for the laboratory workers and its
indiscriminate disposal can have environmental risks as detailed above. The same applies for other
substances, such as untreated and expired drugs, treated samples of food and drugs and sharps
(needles, syringes, broken laboratory glassware etc).
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Rag-pickers, whose livelihood is dependent on the facility are also at risk though infection and
injury. Indiscriminate dumping of wastes can also result in illegal and dangerous recycling of
chemicals, sharps and other substances, which can become a public health hazard.
Poor drainage and infrequent collection resulting in decomposition of wastes around the facility can
encourage breeding of mosquitoes, flies, rats and other scavengers.
4. Legal RequirementsEnvironmental legality
1 Water (Prevention and
Control of pollution)
Act 1974
CPCB Prohibits the discharge of
pollutants into water
bodies beyond a given
standard, and lays down
penalties for non-compliance
Applicable
2 Water (Prevention and
Control of Pollution)
Cess Act, 1977
SPCB Provides for a levy and
collection of a cess on
water consumed by
industries and local
authorities
Applicable
3 Forest (Conservation)
Act 1980, Forest
Conservation Rules,1981
MoEF, Forest
Department
Restrictions on
conversions of Forest
for uses other than
reforestation,
including use for roads
Not
Applicable
4 Air (Prevention and
Control
of Pollution) Act, 1981
CPCB Provides means for the
control and
abatement of air pollution.
Applicable
5 The Air (Prevention
and Control of
Pollution) Rules, 1982
CPCB Defined the procedures for
conducting meetings of the
boards, the powers of the
presiding officers,decision-making etc
Applicable
6 Environment
(Protection) Act 1986
(EPA) followed by
amendment in
May1994 (Schedule-I)
Ministry of
Environment
and Forests
(MoEF)
Ensure that appropriate
measures are taken to
conserve and protect the
environment before
commencement of
operations.
Applicable
7 Environmental Impact
AssessmentNotification no. S.O.
60 (E) 1994,
Under its ambit, 32 types
of industries are liable toopt for Environmental
clearance from MoEF, by
providing adequate EIA
Applicable
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report
8 The Environment
(Protection) Rules,
1986
Lay down the procedures
for setting standards of
emission or discharge of
environmental pollutants
Applicable
9 The Hazardous Wastes
management(Management and
Handling) Rules, 1989
Procedure for inventory,
control, handling anddisposal of hazardous
waste. Provide for setting
up of disposal sites/landfill
sites design, operation and
closure
Applicable
10 Bio Medical Waste
(Management &
Handling) Rules, 1998
Provide for collection,
segregation,storage,
treatment and disposal of
biomedical wastes
according to the
standards and procedures
Not
Applicable
5.Objectives and TargetTransparency
Target: 100 percent of manufacturing and research and development facilities will provide facility- or
company-specific environmental sustainability information to the public.
Water Cleanliness & Usage
Objective: 1. To reduce kLD (Thousands of Level Detectors) level in disposed water by 20% from 2010
level.
2. To reduce the water usage by 10% from 2010 level.Target:
1. Improving the recovery of solvents from disposed water upto 99.5%
2. Establishing and following standard work practices to reduce wastage of water during any process
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Air Quality
Objectives:
1. To reduce the suspended particulate matter in discharged air by 20% from 2010 level.2. To reduce the emission of hazardous gases by 20% from 2010 level.
Target:
1. Implementing the Air Quality program2. To keep all the ventilation systems upgraded and maintained.3. To implement a regular inspection and monitoring program to ensure all devices all working
properly.
4. Reduce air emissions through process change and emission controls by microscale chemistry.5. Establishing a high purity solvent delivery system
Diposal of Hazardous Waste
Objective:
1. To establish a proper hazardous waste disposal systemTarget:
1. Labelling of Hazardous waste2. To fix closed container with lids for hazardous waste collection3. To select the proper site for landfill.
Environmental Literacy
Target: Increase employee awareness and understanding of global environmental issues.100 percent of
facilities have a five-year literacy plan and implement one environmental education campaign each year
from 20062010
Compliance
Target: Zero accidental releases; zero government-issued violations.
Done By:-
Sandeep Goel (Sec-2), 1083
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6. EMS Implementation in Pharmaceutical LaboratoriesLike any other important business activity in a lab, environmental issues must be carefully managed. For
example, important business activities occurring in labs address quality, finance, human resources, or safety
and have appropriate management systems.
The collection of activities undertaken to ensure that environmental issuesare managed is called an
environmental management system (EMS). AnEMS is essential to:
o Consistently comply with environmental laws and regulations;o Improve overall environmental performance;o Address environmental liability from current or past practices;o Maximize the investment, no matter how small, in environmental affairs;o Integrate environmental objectives into overall business objectives; ando Provide for an environmentally safe workplace.
Implementation
o Establish roles and responsibilities and provide resources.o Provide training to employees on their environmentalresponsibilities.o Institute processes for communicating both internal and externalenvironmental management issues.o Develop written procedures and policies and ensure thatdocumentation is maintained.o Identify potential emergencies and develop procedures forprevention and response.
7. Resources, Roles, Responsibility and Authority
Head from each department will be the part of the EMS core team who will make further another team
consisting of subordinates and workers of his team.
Through a common meeting, consisting of all the employees and workers and head of the team who will be
the GM category person (Top Management), will make each person acquainted with the environmental
policy and objectives and targets.
Each department head will take care of the objectives and targets set for his department and in conjugation
with other department will develop new strategies through brain storming.
Using Delphi technique in which experts of different fields like air, water, soil, waste disposal in
pharmaceuticals sector are invited.
Head of the team will be responsible for budget allocation, reviewing the progress and guiding the core team
members of different departments.
Each department head in consultation of team head and the expert from outside will work out the plan and
execute the plan to reduce chances of accidents, looking for all the environmental aspects of that area
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designing the new processes, their implementation and assessing the results and reporting to top
management.
Employees of that department at middle level will be given responsibilities to fill the checklist prepared.
Measuring the effects of changed and improved practices on daily basis. A standard approved checklist will
be maintained by them.
Workers at bottom level who are involved in implementation will be given due importance and their in-
charge have to continually motivate them and let them understood the importance of EMS.
8. Training, Awareness and CompetenceEnvironmental Training
A critical element for the successful implementation of a lab EMS is the development and implementation of
an environmental training program. Employees mayencounter various types of hazardschemical, physical,
biological, radiological etc. Acomprehensive training program provides:
Employees with information to conduct their jobs in a safe manner
A process to assure compliance with regulatory-based training requirements Mechanism which demonstrate managements commitment to improved environmentalPerformance. Communicate corporate environmental policies and goals Elevate the environmental awareness of staff
Done By
Sampath Gelam, Sec 2, 1082
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classroom training.Computer-based training isincreasingly being applied as aneffective teaching method.
9. Communication
For any training program its important to know the way and medium of communication according to the
executives to be trained. The main aim should be delivering a better training program which helps in
uplifting the knowledge base and workforce way of working in the organization, with keeping in mind to
enhance the performance of the executives for the required issue. Even inventing new and better
technological ways are there in scenario but the training program head should know the limits according to
the audience group.
10. Environmental Management System Documentation
In order to be in conformance with this provision of ISO 14001(4.4.4) an organization must be able to
answer the overall question: "What level of documentation is needed?". In order to answer that question
three specific tasks must be addressed under the Environmental Management System Documentation section
of the standard.
The organization must describe the foundation elements of the environmental managementsystem in either paper or electronic format.
The preceding description mustdemonstrate the interaction between the foundation elements of theenvironmentalmanagement system.
The description must reference the related documentation.
The use of the word "document" in ISO 14001 provides a direct reference to whatare the foundation
elements of the environmental management system. Where is theword "document" used in the standard?
For any further the documentation should be in compliance with ISO 14001 and fulfill all the needs for
external and internal auditing.
11. Monitoring of Implementation
Every laboratory must have an environmental health and safety officer (EHSO) to organize different
activities and monitor the implementation of the environmental plan. Routine monitoring would be done by
EHSO at laboratory level. He/she will be responsible for maintaining records as per the agreed protocols. In
addition, two health, safety and environmental surveys would be undertaken (once during mid term another
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before project closure) by a competent independent agency. Environmental audit will be taken up along with
technical audit of the food and drug laboratories. It should have compliance with both food department of
India and health department.
Outputs:
i) Compliance reports/records
ii) Inventory of hazardous material and Material safety data sheets
iii) Audit reports
Done By:-
Eshan Gupta (Sec 2, 1065)
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12 Emergency Preparedness
Spill Containment: The need for spill protection applies to all areas where materials can be potentially
damaging. The following are some steps to prevent spills from entering drains.
Floor drains should be eliminated from new construction. Where floor drains presently exist, they shouldbe covered with properly fitting drain covers. Have spill kits available where required or where spills are likely to enter drains.
Further requirements for emergency preparedness
A communications device or alarm system capable of informing facility personnel and local emergencyresponse authorities in the event of an emergency.
Portable fire extinguishers (including special extinguishers, foam, and dry chemical, necessary for thewaste), spill control equipment, and decontamination equipment.
Water at adequate volume and pressure to supply water hose streams, foam producing equipment, orautomatic sprinklers.
Waste containers must be arranged in the accumulation area so that there is adequate aisle space toallow access for emergency personnel and equipment
The following information must be posted next to the telephone in the area:o Name and phone number of the emergency coordinator, ando Location of the spill control material, fire alarm, and fire extinguishers and telephone number of the
local fire department unless there is a direct alarm.
Done By:-
Gautam Gulshan (Sec-2, 1066)
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13. Non Conformance and corrective and preventive action
Since XYZ is a leading analysis and research group, providing complete solutions for improving quality in
processes, products and services. XYZ provides calibration of production & quality control equipment with
traceability to national / international standards. This means that your equipment are precise and thereforereducing the probability of end-product defects / rejects. More over it caters to a large number of clients with
varied interests. Due to this, there are good chances for non conformance in terms of EMS.
XYZ should have following proper procedures for inquiry and corrective measures:
Determine the cause: Why the non-conformance has occurred ? What are the reasons behind it?Whether it was avoidable in nature? What can be its frequency? Is there any documentation of the
nonconformance or not?
Decide if immediate action is required: If the impact of nonconformance is great and catastrophicthen there is will be immediate need of corrective actions. It should be recognised as early with
proper course of action to deal with it.
Decide which action should be taken: An appropriate set of action is required for dealing with thefull efficiency to the non-conformance occurred. There should be documentation of each of such
incidences in order to have a proper guideline for the approach required.
Check to see if measures are effective:There should be repetitive scrutiny of the non-conformanceand the action taken to judge the extent of the effectiveness of the action and the level of success
achieved in dealing with non-conformance.
Record shortcoming of Corrective Actions: For the purpose of the proper guideline and futurereference there should be proper documentation of the shortcomings and the problems in action on
the event. This will help in research work for dealing with the similar problems more effectively.
Record changes in procedures required to avoid duplication: With the each new non-conformance of similar type there will be change in the approach to it and this should be properly
documented and preventive measurements should also be indicated in order to avoid any duplication
of shortcoming in future.
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14. Records
Records are required to demonstrate compliance with the EMS. Theyre collected within the framework of
the EMS, and they record the extent to which the EMS design is performing. Procedures are developed to
maintain, identify, collect, index, and store records. Included in the records being maintained by the system
are contractor, procurement, audit, management review, and training records necessary for the confirmation
of the EMS. The retention and maintenance of records associated with your EMS serve several purposes.
Primarily, these records are the evidence of an effectively operated EMS. This evidence must be shown to
registrars and auditors to verify that your EMS conforms to the ISO 14001 Standard. Also, these records
may include procedures that have been removed from service which are retained for an operational history
of mothballed equipment or to retain operating expertise for techniques that have been supplanted.
For the purpose of XYZ, as the organization deals with multiple procedures there is a need of recording all
the procedures, events, data and the course of action for it. There should be always some documentation of
the each and every action related to the working in XYZ. Some of the records that should be maintained in
XYZ's EMS which are specific to different fields of working include:
Inspection and monitoring data. Calibration and maintenance records for instrumentation. Non-conformance and corrective actions records and reports. Record of updates in compliances and measures.
Handling, storage and procurement record. Air, Water & hazardous waste discharge record. Non-hazardous solid waste records. Hazardous substance releases record. Radio-active & special waste record. Sustainable practices record.
15 Environmental management system audit
External auditing is recommended for ISO 14001 EMS. Further, EPA requirements for their Self-Policing
Policy, and Star Track Program includes independent auditing. The neutral vision of the auditor is at the
core of this concern. The intent of auditing is to supply management with better vision from which they
make decisions. In-house staff may not be comfortable delivering completely objective information critical
enough to be useful for system modification.
XYZ shall insure that the EMS audits are conducted at an interval of 3 months at least with the objectives of
:
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Determine whether the EMS system conforms the planned arrangements for environmentalarrangement including the requirement of standards and hence been properly implemented and
maintained.
Provide information on the result of audits to management.
Audit programmes of the XYZ shall be planned, established, implemented and maintained by the
organization, taking into consideration the environmental importance of the operations concerned
and the result of previous audits. Audits procedures shall be established, implemented and
maintained that addresses the responsibilities and requirement for planning and conducting audits,
reporting results and retaining associated records and determination of audits criteria, scope,
frequency and methods.
16 Management Review
Top management shall review the XYZs EMS, at interval of 3 months. This interval could be shorten also
if considered necessary. Management review should be done to ensure the XYZs EMS continuing
suitability, adequacy and effectiveness. Reviews shall be used for the enhancing performance to cater the
clients. Reviews shall include accessing opportunities for improvement and the need for changes to the
EMS, including the environmental policies, targets and objectives. Records of management reviews shall be
retained. Since XYZ is into contract testing and analysis so it highly depends of the frequent reviews and
feedbacks.
Input to management reviews shall include.
1. Communication and complaints of the clients and other external bodies.2. Overall performance of the organization.3. Performance in achieving targets and goals.4. Results of internal audits and the evaluation of compliance with legal requirements.5.
Status of corrective and preventive actions.
6. Previous management reviews.7. Feedbacks from the staff directly affected and involved with the operations.8. Recommendation for improvement.9. Changes in the international & national standards.10.Other developments in the legal & political issues.
This review shall contribute to any of the managerial decisions be it be of any kind.
Done By:-
Shubham (Sec2, 1086)