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PROCEDURE FOR INTERNAL
       AUDITS
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                                                  PROCEDURE NO. :
                                                  REV. NO. 0 DATE:
             PROCEDURE FOR INTERNAL AUDITS
                                                  PAGE   1   OF   5
                  PROCEDURE FOR INTERNAL AUDITS
   0                 First issue
REV. NO.   DATE                    BRIEF RECORD OF REVISIONS
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                                                           PROCEDURE NO. :
                            PROCEDURE FOR                  REV. NO. 0        DATE:
                            INTERNAL AUDITS
                                                           PAGE   2     OF    5
1.0     OBJECTIVE
        To conduct Health, Safety & Environmental audits and to assess the
        effectiveness of HSE management system.
2.0     SCOPE
        This procedure covers all activities performed at project sites and offices.
3.0     RESPONSIBILITY
        MR/MA and qualified Internal Auditors.
4.0     PROCEDURE:
4.1     Audit checklists for Health, Safety and Environment
4.1.1   The Health, Safety and Environment (HSE) audit checklists are developed
        covering the following activities/areas.
          1)    Records
          2)    Safety Training
          3)    Safety Promotion
          4)    Housekeeping
          5)    Ladders
          6)    Scaffolding
          7)    Electrical
          8)    Excavation
          9)    Welding
          10)   Fire Prevention
          11)   Use of Personal Protective Equipment
          12)   First Aid
          13)   Fall Protection
          14)   Builder Hoist
          15)   Cranes
          16)   Power Tools
          17)   Miscellaneous
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                                                        PROCEDURE NO. :
                       PROCEDURE FOR                    REV. NO. 0        DATE:
                       INTERNAL AUDITS
                                                        PAGE   3     OF    5
4.1.2   SE/SS to conduct HSE audits at least once a month using the checklists and
        the status of implementation / compliance shall be reported to PM.
4.1.3   PM to ensure that corrective actions are taken to rectify non-compliances
        reported and informs Head - HSE Management accordingly.
4.1.4   SE/SS to prepare site specific new checklists if new activities other than
        identified above are taken up. SE/SS to revise the checklists to incorporate
        any new requirements based on the site specific requirements.
4.1.5 The Internal Audit of the HSE Management System is conducted at
      least twice in a year. Frequency of internal audit is increased, if
      required, based on results of previous audit.
4.2     Audit is conducted by Internal Auditors provided with adequate training
        by competent external agency and the list of such trained auditors is
        maintained by MR. If necessary, MR also decides to take the help of
        external trained auditors to assist in internal auditing.
4.3     MR decides the annual audit plan at the beginning of the year for
        Internal HSE Management System Audit.
4.4     Audit Planning & Scheduling
4.4.1 MR/MA identifies areas for audit based on HSE importance, the
      current status of HSE system, the results of Aspect & Hazard
      assessment of activities concerned and the results of previous audits.
      MR/MA prepares a schedule in consultation with various HODs and
      circulates the schedule to auditors & auditees.
4.4.2 MR/MA decides the scope of audit for each of HSE Management
      System element based on discussion with concerned PMs and
      selects the internal auditors who are independent of the area to be
      audited.
4.4.3 MR/MA provides the internal auditors with information about the
      previous audit findings, if any, to check the effectiveness of corrective
      action taken and revalidation.
4.4.4 MR/MA ensures cordial relationship between the auditor and auditee.
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                                                      PROCEDURE NO. :
                       PROCEDURE FOR                  REV. NO. 0        DATE:
                       INTERNAL AUDITS
                                                      PAGE   4     OF    5
4.5    Conduct of the Audit
4.5.1 Internal auditors carry out audit based on
       a. HSE Management System Manual, Procedures, OCPs.
       b. Relevant HSE records.
       c. Aspects / Impacts and Hazards & Risks identified and their
            results.
       d. HSE Management Programs
       e. Relevant Legal regulations & other requirements.
       f. Previous audit results.
4.5.2 The auditor, when observes nonconformity, shall raise NCR in format
      which will contain observations, proposed corrective actions, actions
      taken. The auditor shall record the nonconformity & the auditee shall
      record the disposition & proposed corrective actions in NCR. Original
      copy shall be given to MR/MA & a copy to the auditee. A copy is
      retained with the auditee for reference.
4.5.3 Classification of observations raised during Audit include
       Observations for Improvement
       a) Minor non-conformities that can be corrected immediately.
       b) Targets not achieved but there is considerable improvement and
          system is in place.
       c) Documents not updated / signed, but right system is followed.
       Non-conformities Minor & Major
       a)   Repetition of previous non-conformity.
       b)   System requirements are not addressed.
       c)   Deviations from Documented system.
       d)   Management is deviating from its responsibilities.
       e)   Non-compliance to legal requirements.
       f)   Major grievances from interested parties.
4.5.4 Internal audit summary sheet is prepared by MR which forms an input
       for Management Review Meeting.
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                                                     PROCEDURE NO. :
                      PROCEDURE FOR                  REV. NO. 0        DATE:
                      INTERNAL AUDITS
                                                     PAGE   5     OF    5
4.6    Follow-up Action
4.6.1 The auditee on completion of disposition & corrective actions will
      intimate auditor/MR so that auditor/MR can verify the implementation
      & effectiveness of corrective actions which will be recorded in NCR. If
      the corrective action is effective and found to be satisfactory the non-
      conformity is closed.
4.6.2 If the auditor could not fully verify the effectiveness of corrective
       actions, he will endorse accordingly and which will then be verified in
       the follow up audit. In such cases, MR/MA will organise a separate
       follow up at a later date or can organise for verification during next
       cycle of audit. MR/MA retains the original copy of NCR & a copy
       shall be given to the auditee.
4.6.3 Wherever any non-conformity & corrective actions occurring in one
      identified area can be extended to other areas, MR will advise the
      concerned HODs to implement such corrective actions as preventive
      actions.
4.6.4 MR/MA prepares a consolidated report on the internal audit
      observations for submission in Management Review Meetings.
4.6.5 Un-scheduled audits may also be undertaken as per discretion of
       MR/MA under the following circumstances
       a. In case of repetition of same non-conformities in that area
       b. If the number of non-conformities are more in that area
       c. Introduction of new process / activity.
       If any change in the statutory / regulatory requirements.
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