EHQMS System Manual

Quality management input comprises the standard requirements from ISO 9001:2015 which
are deployed by our organisation to achieve customer satisfaction through process control.

Environmental input comprises the standard requirements from ISO 14001:2015 which
provides our organisation with a framework to help protect the environment and respond to
changing environmental conditions.

Occupational health and safety management input meets the requirements of ISO 45001:2018
to encourage a safe and healthy workplace and prevent work-related injury and ill-health.

INTEGRATED MANAGEMENT
SYSTEM
 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

APPROVAL
The signatures below certify that this management system manual has been authorised and demonstrates that
the signatories are aware of all the requirements contained herein and are committed to ensuring their provision.

Name Signature Position Date

Prepared by Amy Walters General Manager 21.05.2023

Reviewed by Jamie McConaghy Technical Director 21.05.2023

Approved by Richard Hemingway Sales Director 21.05.2023

AMENDMENT RECORD
This management system manual is reviewed to ensure its continuing relevance to the systems and process that
it describes. A record of contextual additions or omissions is given below:

Page No. Context Revision Date

COMPANY PROPRIETARY INFORMATION

The electronic version of this document is the latest revision. It is the responsibility of the individual to ensure
that any paper material is the current revision. The printed version of this manual is uncontrolled, except when
provided with a TM System Document reference Number.

Document Ref. TMS-IMS01 Page 1 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Table of Contents
TABLE OF CONTENTS ................................................................................................................................................ 2
1 INTRODUCTION ................................................................................................................................................... 5
2 REFERENCES ...................................................................................................................................................... 6
3 DEFINITIONS ....................................................................................................................................................... 6
4 ABOUT OUR ORGANISATION .............................................................................................................................. 7
ORGANISATIONAL CONTEXT ..................................................................................................................................... 7
RELEVANT INTERESTED PARTIES ............................................................................................................................. 8
MANAGEMENT SYSTEM SCOPE ................................................................................................................................. 8
MANAGEMENT SYSTEM PROCESSES ......................................................................................................................... 9

5 LEADERSHIP, COMMITMENT AND WORKER PARTICIPATION .......................................................................... 11

LEADERSHIP & COMMITMENT ................................................................................................................................. 11
5.1.1 General ...................................................................................................................................................... 11
5.1.2 Customer Focus ........................................................................................................................................ 12
MANAGEMENT SYSTEM POLICIES............................................................................................................................ 12
5.2.1 Establishing our Policies .......................................................................................................................... 12
5.2.2 Communicating our Policies .................................................................................................................... 12
ROLES, RESPONSIBILITIES AND AUTHORITIES .......................................................................................................... 13
5.3.1 Top Management ...................................................................................................................................... 13
5.3.2 General Manager ....................................................................................................................................... 13
5.3.3 Quality Inspectors ..................................................................................................................................... 13
5.3.4 QHSE Committee - Environmental ........................................................................................................... 14
5.3.5 QHSE Committee – Health & Safety ......................................................................................................... 14
5.3.6 Managers & Supervisors ........................................................................................................................... 14
5.3.7 Workers & Contractors ............................................................................................................................. 14
CONSULTATION & PARTICIPATION OF WORKERS AND CONTRACTORS ......................................................................... 15

6 PLANNING ......................................................................................................................................................... 16
GENERAL ............................................................................................................................................................. 16
6.1.1 Risks & Opportunities ............................................................................................................................... 16
6.1.2 Environmental Aspects ............................................................................................................................ 17
6.1.3 Hazard Identification & Assessment ....................................................................................................... 18
6.1.4 Compliance & Legal Requirements.......................................................................................................... 18
6.1.5 Planning Action ......................................................................................................................................... 20
MANAGEMENT SYSTEM OBJECTIVES....................................................................................................................... 20
6.2.1 Integrated Objectives ............................................................................................................................... 20
6.2.2 Objectives & Planning to Achieve Them .................................................................................................. 21
PLANNING FOR CHANGE ........................................................................................................................................ 22

7 SUPPORT.......................................................................................................................................................... 24
RESOURCES ......................................................................................................................................................... 24
7.1.1 General ...................................................................................................................................................... 24
7.1.2 People........................................................................................................................................................ 24

Document Ref. TMS-IMS01 Page 2 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

7.1.3 Infrastructure & Natural Resources ........................................................................................................ 24

7.1.4 Operational Environment ......................................................................................................................... 25
7.1.5 Monitoring & Measurement Tools ............................................................................................................ 25
7.1.6 Organisational Knowledge ....................................................................................................................... 26
COMPETENCE ....................................................................................................................................................... 26
AWARENESS ........................................................................................................................................................ 27
COMMUNICATION................................................................................................................................................... 28
7.4.1 General ...................................................................................................................................................... 28
7.4.2 Internal Communication ........................................................................................................................... 28
7.4.3 External Communication .......................................................................................................................... 28
DOCUMENTED INFORMATION .................................................................................................................................. 29
7.5.1 Management System Documents ............................................................................................................ 29
7.5.2 Creating & Updating ................................................................................................................................. 30
7.5.3 Controlling Documented Information ...................................................................................................... 30

8 OPERATION ....................................................................................................................................................... 31
OPERATIONAL PLANNING & CONTROL..................................................................................................................... 31
8.1.1 Quality Operational Planning & Control .................................................................................................... 31
8.1.2 Environmental Operational Planning & Control....................................................................................... 31
8.1.3 OH&S Operational Planning & Control ..................................................................................................... 32
DETERMINING REQUIREMENTS FOR PRODUCTS......................................................................................................... 33
8.2.1 Customer Communication ....................................................................................................................... 33
8.2.2 Determining Requirements ...................................................................................................................... 33
8.2.3 Reviewing Requirements .......................................................................................................................... 34
8.2.4 Changes in Requirements ........................................................................................................................ 34
DESIGN & DEVELOPMENT ...................................................................................................................................... 34
8.3.1 General ...................................................................................................................................................... 34
CONTROL OF SUPPLIERS, EXTERNAL PROCESSES AND CONTRACTORS ....................................................................... 34
8.4.1 General ...................................................................................................................................................... 34
8.4.2 Purchasing Controls ................................................................................................................................. 35
8.4.3 Purchasing Information ............................................................................................................................ 36
PRODUCTION & SERVICE PROVISION ....................................................................................................................... 36
8.5.1 Control of Production & Service Provision .............................................................................................. 36
8.5.2 Identification & Traceability .................................................................................................................... 37
8.5.3 3rd Party Property ...................................................................................................................................... 37
8.5.4 Preservation.............................................................................................................................................. 37
8.5.5 Post-delivery Activities ............................................................................................................................ 38
8.5.6 Control of Changes ................................................................................................................................... 38
RELEASE OF PRODUCTS & SERVICES ...................................................................................................................... 38
NON-CONFORMING OUTPUTS ................................................................................................................................. 39
EMERGENCY SITUATIONS....................................................................................................................................... 39

9 PERFORMANCE EVALUATION .......................................................................................................................... 41

MONITORING, MEASUREMENT, ANALYSIS & EVALUATION ......................................................................................... 41
9.1.1 General ...................................................................................................................................................... 41
9.1.2 Customer Satisfaction ............................................................................................................................. 41
9.1.3 Analysis & Evaluation ............................................................................................................................... 42

Document Ref. TMS-IMS01 Page 3 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

9.1.4 Evaluation of Compliance ........................................................................................................................ 42

INTERNAL AUDIT ................................................................................................................................................... 42
9.2.1 General ...................................................................................................................................................... 42
9.2.2 Internal Audit Programme ........................................................................................................................ 43
MANAGEMENT REVIEW .......................................................................................................................................... 43
9.3.1 General ...................................................................................................................................................... 43
9.3.2 Inputs ......................................................................................................................................................... 43
9.3.3 Outputs ...................................................................................................................................................... 44

10 IMPROVEMENT ............................................................................................................................................. 46
GENERAL ............................................................................................................................................................. 46
INCIDENT, NON-CONFORMITY & CORRECTIVE ACTION............................................................................................... 46
10.2.1 Non-conformity & Corrective Action ....................................................................................................... 46
10.2.2 Incident Investigation ............................................................................................................................... 47
IMPROVEMENT ...................................................................................................................................................... 47

APPENDICES ........................................................................................................................................................... 49
A.1 QEHS PROCESS INTERACTION ............................................................................................................................... 49
A.2 ORGANISATION CHART........................................................................................................................................... 50

Document Ref. TMS-IMS01 Page 4 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

1 Introduction
TM Steels Limited has developed and implemented an integrated Quality, Environmental and Occupational Health
& Safety Management System, which uses ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018 as framework for our
organisation to document and improve our operational practices in order to better satisfy the needs and
expectations of our workers, customers, stakeholders and interested parties.
This management system manual is used to familiarise our workers, customers, interested parties, or individuals
with the controls that have been implemented and to assure them that the integrity of our management system
is maintained and is focused on meeting its intended outcomes.
This manual also describes the structure and interactions of our management system, delineates authorities,
inter relationships and responsibilities of personnel who operate within the boundaries of TM Steels’ integrated
management system (IMS), whilst providing reference to the procedures, process and activities that comprise it.
The Figure below illustrates our methodology for the development of our integrated management system, which
uses the plan, do, check and act cycle to implement the process approach that delivers management system
objectives, stakeholder requirements and customer satisfaction.
Figure 1: Integrated Management System Process Model

Internal & External Issues Needs & Expectations of Interested Parties

Context of the Organisation

Scope of the IMS

Planning

PLAN

Operation

ACT Leadership,
Commitment & Support &
Improvement
Worker Operation
DO
Participation

CHECK

Performance
Evaluation

Certification to the international standard ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018 will help achieve
these intended outcomes and demonstrates that the IMS is effective, provides value for TM Steels and its

Document Ref. TMS-IMS01 Page 5 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

interested parties. Our management system addresses and supports our wider strategies for the sale of Steel TM
Steels Limited, Sheepbridge Works, Chesterfield, S41 9QD, UK.
Our scope includes the management of billet, bars (forged, rolled, cold drawn and ground); forging, machining,
heat treating and associated testing, to customer specified requirements/industry standards, with source/lot
traceability of manufacturing batches.
The following table identifies any ISO 9001:2015 requirements, from Section 8.0, that are not applicable to our
organisation as well as providing a brief narrative to justify their omission from the scope of our IMS:

Clause Justification for Exclusion

8.3 TM Steels do not design or develop products. We supply only to customer drawing or specification.

2 References
In addition to ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018, we also make reference to other relevant national
or International standards as well as customer specifications appropriate to our context.

Standard Title Description

BS EN ISO 9000:2015 Quality management systems Fundamentals and vocabulary
BS EN ISO 9004:2000 Quality management systems Guidelines for performance improvements
BS EN ISO 19011:2011 Auditing management systems Guidelines for auditing
BS EN ISO 14004:2016 Environmental management systems Guidelines for implementation

3 Definitions
This document does not introduce any new definitions but rather relies on the following:
1. Definitions typically used by our customers, stakeholders or marketplace;
2. Terms typically used in standards and regulations as they relate to our products and services;
3. Standard business terminology;
4. Terms and vocabulary commonly used in quality and manufacturing practices.

Document Ref. TMS-IMS01 Page 6 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

4 About Our Organisation

Organisational Context
TM Steels is committed to defining our position in the Figure 2: Examples of Internal & External Influences
marketplace and understanding how relevant factors
arising from legal, political, economic, social and
technological issues influence our strategic direction Types of internal Types of external
and our organisational context. influence influence

TM Steels identifies, analyses, monitors and reviews Directors Stakeholders

factors that may affect our ability to satisfy our
Shareholders
customers and stakeholders, as well as; factors that Legislators
may adversely affect the stability of our processes and Trustees
the integrity of the management system. Regulators
Workers
To ensure that our management system is aligned with Consumers
our strategy, whilst taking account of relevant internal Contractors
and external factors; we initially collate and analyze Media
Culture
pertinent information in order to determine potential
impact on our context and subsequent business Knowledge Community
strategy.
Such issues include factors that are affected by our organisation or can affect our organisation. Broadly, these
issues are defined as:
1. Internal issues – conditions related to our organisational activities, products, services, strategic
direction, culture, people, knowledge, processes and systems. Using SWOT analysis provides our
organisation with framework for reviewing and evaluating our strategies, and the position and direction
of our organisation, business propositions and other ideas;
2. External issues – conditions related to cultural, social, political, legal, regulatory, financial,
technological, economic, competition at local, national or international levels. Using PESTLE analysis
provides our organisation with framework for measuring our market and growth potential.
TM Steels then monitors and reviews this information to ensure that a continual understanding of each group’s
requirements is derived and maintained. To facilitate the understanding of our context, we regularly consider
issues that influence our context during management review meetings using the Context & Interested Parties
analysis template. The results of which are conveyed via minutes and business planning documents. We maintain
and retain; in addition to this document, the following documented information to describe our organisational
context and decisions relating to it:
1. Context & Interested Parties analysis underpins our policies and drives our future goals;
2. Analysis of business plans, strategies, and statutory and regulatory commitments;
3. Analysis of technology and competitors;
4. Economic reports from relevant business sectors;
5. Technical reports from technical experts and consultants;
6. Minutes of meetings (Management and design review minutes), process maps and reports, etc.
The outputs from these activities are evident as an input to determining the scope of our management (4.3) and
its processes (4.4), as well as, the consideration of risks and opportunities that may affect the IMS, and the
resulting actions that we take to address them (6.1).

Document Ref. TMS-IMS01 Page 7 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Relevant Interested Parties

TM Steels identifies and classifies its interested parties, based on current information and knowledge held within
our business. Each interested party is allocated to one or more categories and is analyzed to determine whether
any relevant needs or expectations exist, which could
Figure 3: Types of Interested Party
impact our business activities or the IMS, and which
must be adopted by the organisation.
Using the Context & Interested Parties analysis template,
Consumers
interested parties and their requirements are ranked
and scored using simple, subjective criteria to create a
Risk Potential Number (RPN). This is calculated by
multiplying the perceived power score, by the priority Community Regulators
score, by the relevance score.
Prioritised relevant needs or expectations are converted Parties that may
be affected by our
into requirements which become inputs to IMS planning. organisation's
The outputs from this process are typically used to activities
inform the following sections and processes of the IMS:
1. Management system scope - 4.3; Trustees Suppliers

2. Management system processes - 4.4;

3. Risk and opportunities - 6.1.1;
4. Environmental aspect and impacts - 6.1.2; Media

5. OH&S hazard identification and assessment -

6.1.3;
6. Compliance obligations and legal requirements
- 6.1.4;
7. Communication - 7.4;
8. Operations - 8.0.
TM Steels recognises that we have a unique set of interested parties whose needs and expectations change and
develop over time, and furthermore; that only a limited set of their respective needs and expectations are
applicable to our operational purpose.

Management System Scope

Based on the scope of our activities described in Section 1 - Introduction and the analysis of the issues and
requirements identified in Sections 4.1 and 4.2, TM Steels has established the scope of our environmental
management system in order the implement the objectives and policies that are relevant to our context, physical
and organisational boundaries, product life cycles and any interested parties.
TM Steels can exert authority and differing levels of control and influence over our activities, as they relate to our
products and services, as performed at our facilities. The functional and organisational boundaries for the
different physical locations (where applicable) and the level of control and influence are summarised below:

Authority to Control or
Physical Boundary Functional Boundary Organisational Boundary
Influence
Our facilities at the
following address: All activities performed and
Complete organisational We have a high degree of
TM Steels Limited, managed by our organisation
control over current authority in order to control or
Sheepbridge Works, which result in product or service
activities influence related processes
Chesterfield S41 9QD outputs
UK.

Document Ref. TMS-IMS01 Page 8 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Authority to Control or
Physical Boundary Functional Boundary Organisational Boundary
Influence

External process 3rd Parties are controlled and

Undertaking process as per our Purchasing and
performed by 3rd influenced through contractual
specifications contractual controls
parties mechanisms

In order for our management system to be robust, all the activities, products and services undertaken by TM Steels
are included with in the scope of the IMS. In this way, we are able to control and influence our activities, products
and services.
The scope of this document describes our IMS, delineates authorities, inter-relationships and responsibilities of
process owners and personnel that operate within management system and the sequence and interaction of our
processes. Conformance to ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018 has been verified utilising a formal
assessment and review process undertaken.
Although we recognize that ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018 does not require a formal manual,
we have decided to retain and update our integrated manual, as our employees, customers, suppliers and other
stakeholders perceive it to add value to our operations.

Management System Processes

TM Steels has implemented an IMS that exists as part of a larger strategy that has established, documented and
implemented our processes, integrated policies and objectives, whilst satisfying the requirements of ISO
9001:2015, ISO 14001:2015 and ISO 45001:2018.
To achieve this, TM Steels has adopted the process approach advocated by the above management system
standards. Top management has determined the processes required for achieving the intended outputs. Refer to
the Process Matrix & Application template that is used to record and assign requirements to relevant functions,
processes, departments and teams. This information forms the basis for programming process audits.
By defining three key process-groups, and by managing their Figure 4 : Key Process Groups
inputs, activities, controls, outputs and interfaces, our
organisation ensures that system effectiveness is established 1. Management &
Review Processes
and maintained. These process groups are described using
tools such as procedures, process maps, turtle diagrams,
Integrated
matrices, schedules and charts, etc. 2. Operation &
Management
Production Processes
Refer to Appendix A.2 for the sequence of our processes and System
the interaction of the processes within our IMS. It is recognized
that defining, implementing and documenting our integrated 3. Support & Assurance
Processes
management system is only the first step towards fully
implementing its requirements.
The monitoring of key performance indicators (KPIs), which are linked to our objectives, is used to measure and
communicate process performance. This approach allows Top management to regularly review management
system performance and to ensure its ongoing integration with business processes.
As part of the decision-making process; we use trends and statistical data and trends related to non-
conformities, environmental, quality and OH&S related aspects, targets, objectives and corrective actions, as well
as, monitoring and measurement results, audit results, levels of customer satisfaction, process performance
data and compliance data, to ensure that objective management decisions can be made.
Where TM Steels identifies the requirement to outsource any process, or part thereof, which affects conformity
with the stated requirements; TM Steels identifies control criteria such as; the competence of workers and

Document Ref. TMS-IMS01 Page 9 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

contractors, inspection regimes, the provision of product conformity certificates, adherence to specifications
and specific job files, etc.

Supporting documentation:
Ref. Title & Description
01 Organisational Context Procedure

Document Ref. TMS-IMS01 Page 10 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

5 Leadership, Commitment and Worker Participation

Leadership & Commitment
5.1.1 General
Top management is actively involved in maintaining the quality, environmental and OH&S management system. It
provides the vision and strategic direction for growth of our integrated management system, and establishes the
necessary objectives and policies taking into account the context and strategic direction of our organisation.
To continue to provide leadership and show commitment to the improvement of our quality, environmental and
OH&S management system, Top management communicates the importance of fulfilling customer, legal and
regulatory compliance requirements through periodic communication meetings as well as by conducting
management reviews to ensure the availability of resources, that risk assessments are understood and the
integrated management system achieves its intended results.
Top management provides accountability and governance to all activities related to the lifecycle of our processes
and products. This includes defining the appropriate responsibilities, authorities, and methods of communication
to ensure the safe and effective performance. Top management ensures that all necessary resources,
responsibilities and accountabilities are allocated for the continual improvement of the management system.
Refer to Appendix A.2 for a copy of our Organisation Chart.
Top management have appointed the General Manager to ensure that the necessary financial, technological and
organisational resources, including the services of specialists and competent Health & Safety Advisors,
Environmental Coordinators and Quality Inspectors are available to implement monitor, maintain and report upon
the status of the management system.
Cross-functional committees that comprise various organisational levels, functions and work areas are
established to support the active management of our integrated system. The Cross-functional committees
oversee the implementation of improvement plans. The Cross-functional committees report to Top management
and the General Manager.
Regular reviews and data reporting ensure that our management system is effective and has the ability to react
to emerging issues. Top management is committed to implementing and developing the management system and
this commitment is defined by our corporate policies and objectives. Top management’s involvement and
commitment may be found in:
1. Business strategy plans and meetings;
2. Management system goals, their communication and their incentivisation.
3. Information provided on our website or social media channels;
4. Annual reports;
5. Management meeting minutes.
Top management ensures that our corporate policies are understood, implemented and maintained throughout
at all levels of the organisation through printed distribution of policy statements and through periodic
management reviews of the policy statements, functional objectives, and corporate level improvement
objectives. TM Steels communicates our mission, vision, strategy, policies and processes to all workers in order
to:
1. Create and sustain shared values of fairness and ethical behaviour.
2. Establish a culture of trust and integrity.
3. Encourage commitment to quality.
4. Provide people with the required resources, training and authority to act with accountability.
5. Inspire, encourage and recognize people’s contribution.

Document Ref. TMS-IMS01 Page 11 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

In addition, our corporate policies, objectives and targets are communicated and deployed throughout the
business via individual, team and department performance objectives which are established and discussed during
employee performance reviews.

5.1.2 Customer Focus

TM Steels strives to identify current and future customer needs, to meet their requirements and to exceed their
expectations. Top management ensures that the focus on improving customer satisfaction is maintained by
setting objectives related to levels of customer satisfaction at management review meetings.
Top management also ensures that customer requirements are understood and met. Customer requirements are
understood, converted into internal requirements, and communicated to appropriate workers and contractors
within the organisation, refer to Section 8.2.2.
Customer complaints and other forms of customer feedback are continually monitored and measured to identify
opportunities for improvement. We continually look for ways to interact directly with our customers to ensure
that we focus on their unique needs and expectations

Management System Policies

5.2.1 Establishing our Policies
The integrated management system policy acts as a compass by providing the direction and framework for
establishing key corporate level performance measures, as well as related objectives and targets. Top
management ensures that our corporate policies are established and documented, and that the policies are
available to all interested parties via our website.
The General Manager has overall responsibility for defining, documenting, implementing and reviewing our
integrated policies in consultation with the management teams and other workers and contractors, or their
representatives. The policies are reviewed at least annually, as part of the management review programme or at
a frequency determined by:
1. Changes in organisational context (Refer to Section 4.1);
2. Changing needs and expectations of relevant interested parties (Refer to Section 4.2);
3. Risks and opportunities to the IMS (Refer to Section 6.1.1)
4. Environmental aspects presented during planning and operational processes (Refer to Section 6.1.2);
5. OH&S hazards presented during planning and operational processes (Refer to Section 6.1.3 & 8.1);
6. Compliance obligations that are presented through the planning process (Refer to Section 6.1.4).
TM Steels’ integrated policies are communicated to all employees at all levels throughout our organisation via
training, regular internal communications and reinforcement during annual employee performance reviews.
Employee understanding of our policies and objectives is determined during internal audits and other methods
deemed appropriate.
TM Steels is committed to an operating philosophy based on openness in communication, integrity in serving our
customers, fairness and concern for our employees and responsibility to the communities within which we
operate.
Our vision is to exceed customer expectations for environmental, safety, sustainability, cost, delivery and value.
Although the activities contained with our policies are centrally coordinated from our facilities, success of the
policy relies on the participation of everyone, and as such, the policy’s aims are embedded into our processes.

5.2.2 Communicating our Policies

Top management ensures that our corporate policies are established and documented, and that the policies are
available to all interested parties via our website. Our policies are communicated to all employees at all levels

Document Ref. TMS-IMS01 Page 12 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

throughout our organisation via training, regular internal communications and reinforcement during annual
employee performance reviews. Understanding of our policies and objectives is determined during internal audits
and other methods deemed appropriate.

Roles, Responsibilities and Authorities

Job descriptions and the organisational structure are reviewed and approved by Top management for adequacy
as determined by the changing needs and expectations of the interested parties identified in Section 4.2, and any
risk and opportunities presented through the risk management process, Section 6.1. All roles with IMS
accountability and responsibilities (including compliance and legislative requirements) are:
1. Documented in job descriptions
2. Documented in responsibility matrices;
3. Included in an organisation chart specific to the business;
4. Organisational charts are available to all employees;
5. Where contractors are involved, areas of accountability and responsibility are contractually agreed.
The organisation chart defined in Appendix A.2 shows the interrelation of personnel within TM Steels, whilst job
descriptions define the responsibilities and authorities of each role. Some of which are summarized below:

5.3.1 Top Management

Top management are responsible for business planning, development and the communication of our policies,
integrated management system planning, the establishment and deployment of objectives, the provision of
resources needed to implement and improve the management system and for undertaking reviews.
Members of Top management are ultimately responsible for the quality of TM Steels’ products and services since
they control the resources, systems and processes by which conforming work is accomplished.
Top management accepts their legal and moral obligations to ensure, as far as reasonably practicable, a safe and
healthy working environment. Safe systems of work are implemented to protect workers, contractors, and anyone
else who may be affected by our operations, from physical harm. In pursuance of this duty, Top management has
appointed safety specialists to discharge occupational health and safety duties within our operations.

5.3.2 General Manager

The General Manager is responsible for ensuring that any identified risks to quality, the environment or
occupational health and safety hazards are eliminated or reduced at source to As-Low-As-Reasonably-
Practicable (ALARP) and that our organisation’s strategic development does not compromise the intended
outcomes of our integrated management system by;
1. Reporting on the operation of the management system;
2. Ensuring that improvement is taking place;
3. Ensuring that customer focus is promoted throughout the organisation.
4. Ensuring that whenever changes to the IMS are planned and implemented;
5. Ensuring the integrity of the system is maintained during changes;
6. Ensuring that responsibilities and authorities within the IMS are communicated and delegated.

5.3.3 Quality Inspectors

Quality Inspectors support the General Manager to deliver the following:
1. Inspecting products for flaws or defects;
2. Testing items by analysing size, weight, dimensions, etc.;
3. Ensuring the production process meets requirements;

Document Ref. TMS-IMS01 Page 13 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

4. Creating reports of quality control tests;

5. Performing statistical analysis and data analysis.
6. Assisting with internal audits;
7. Fulfilling documentation and reporting requirements.

5.3.4 QHSE Committee - Environmental

QHSE Committee supports the General Manager to deliver the following:
1. Providing advice and information on environmental matters to staff and others as applicable;
2. Coordinating environmental issues with employees;
3. Identifying and assessing environmental aspects and their impacts;
4. Ensuring operational controls are implemented and monitored;
5. Representation at Improvement Groups;
6. Publication of internal communications and environmental newsletters;
7. Completion of audits according to the internal audit programme;
8. Increasing the environmental competence and awareness of staff at all levels through the development
of training and awareness initiatives and sharing of best practice.

5.3.5 QHSE Committee – Health & Safety

QHSE Committee supports the General Manager to deliver the following:
1. Providing advice and information on health and safety matters to staff and others as applicable;
2. Identifying and assessing OH&S hazards and their risks;
3. Ensuring operational controls are implemented and monitored;
4. Coordinating OH&S issues with employees;
5. Representation at Improvement Groups;
6. Publication of internal communications and OH&S newsletters;
7. Completion of audits according to the internal audit programme;
8. Increasing the OH&S competence and awareness of staff at all levels through the development of
training and awareness initiatives and sharing of best practice.

5.3.6 Managers & Supervisors

All Managers and Supervisors demonstrate their commitment to the development and improvement of the
management system through the provision of necessary resources, through their involvement in the internal audit
process and through their proactive involvement in continual improvement activities. Emphasis is placed on
improving both the effectiveness and efficiency of key system processes.
All Managers and Supervisors are responsible for the execution of the business plan and the implementation of
our policies, processes and systems described in this integrated manual. All Managers and Supervisors are
responsible for planning and controlling the management system processes within their area of responsibility,
including the establishment and deployment of operational level objectives and the provision of resources needed
to implement and improve these processes.

5.3.7 Workers & Contractors

All workers and contractors are responsible for the quality of their work and implementation of our policies and
procedures applicable to the processes that they perform. Workers and contractors who are responsible for
product quality have the authority to stop production to correct quality problems.
Workers and contractors are motivated and empowered to identify and report any known or potential problems,
and to recommend solutions to aid subsequent risk management and corrective action activities.

Document Ref. TMS-IMS01 Page 14 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

All workers and contractors are encouraged to participate and engage with occupational health and safety
management processes. At our facilities, TM Steels appoints Health and Safety Representatives and Advisors,
First Aiders and Fire Marshals as required by local conditions, and as determined by documented risk
assessments. Employees who share a workspace are required to cooperate and coordinate their actions to
ensure safe undertakings.

Consultation & Participation of Workers and Contractors

TM Steels recognises that the involvement of workers in the integrated (OH&S) management system and the
processes that support it are a key requirement of effective OH&S management that enables our organisation to
make informed decisions.
Worker participation and consultation is ensured via the engagement of all employees, at all applicable levels and
functions within our organisation. Workers include contractor and agency staff who perform work on-site, as well
our organisation’s direct employees. Time, training, information and resources for participation are provided
whilst obstacles and barriers to participation are removed entirely or minimized when they cannot be removed.
Health & Safety Representatives and Health & Safety Advisors are involved in the following activities, in
conjunction with the relevant workers:
1. Incident investigation;
2. Hazard identification;
3. Risk assessment;
4. Implementing and monitoring appropriate hazard mitigations.
Changes to the management system are controlled via the management of change process to ensure unintended
consequences are recognized, mitigated, or eliminated prior to implementation of the proposed change.
Employees are represented by the Health & Safety Representatives and Health & Safety Advisors in OH&S
matters, and these representatives determine when and how information is communicated.
Top management ensures participation and representation of the workforce in regard to occupational health and
safety matters by promoting the participation of non-managerial roles within the OH&S system requirements,
including incident investigations, work-place assessments, agreeing corrective actions, formulating objectives
and policies, and undertaking monitoring activities such as inspections and internal audits. Other mechanisms for
consultation and participation include focussed team meetings, workshops, worker surveys and suggestion
schemes.

Document Ref. TMS-IMS01 Page 15 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

6 Planning
General
TM Steels considers and manages the risks and opportunities relating to our stakeholders, and our external and
internal context. This process uses the information collected during context and strategy evaluations stakeholder
and interested party analysis, and from the evaluation of any hazards and impacts.
Top management considers the risks and opportunities and takes action to ensure that our management system
meets its intended outcomes and achieves continual improvement. All proceedings and decisions are recorded
in the management review meeting minutes.
Once the significant or material risks and opportunities are identified; from the activities and outputs undertaken
in Sections 6.1.1 to 6.1.5, our organisation plans actions to avoid or mitigate perceived risks, or to take advantage
of opportunities.
Action is taken in a variety of ways using management review meetings, design review meetings, setting
objectives, KPIs and policies, operational control, emergency preparedness, supplier evaluation, and other
appropriate processes.

6.1.1 Risks & Opportunities

The aim of risk and opportunity management within TM Steels is to ensure that organisational capabilities and
resources are employed in an efficient and effective manner to take advantage of opportunities and to mitigate
risk to our strategic direction and business planning (4.1), interested parties (4.2). our management system and
its processes (4.3), our products (8.1) and our suppliers (8.4).
Top management are responsible for incorporating risk-based thinking into our organisation's culture. This
includes the establishment of risk management procedures and processes to ensure the effective risk and
opportunity management principles are undertaken throughout the lifecycle of our management system,
products, services and activities by:
1. Providing sufficient resources to carry out risk and opportunity management activities;
2. Assigning responsibilities and authorities for risk and opportunity management activities;
3. Reviewing information and results from audits and risk and opportunity management activities.
Risk and opportunity management is undertaken as part of TM Steels’ day-to-day operations to capture and react
to perceived risk and opportunity, ensuring each issue is managed at the most appropriate level within our
organisation.
TM Steels has classified its ‘risk appetite’ as the amount of risk that we are willing to accept in pursuit of an
opportunity or the avoidance or mitigation of risk; where each pertains to the conformity of our products,
processes, the management system, and which reflect the following considerations:
1. Risk management philosophy per product or process, and tolerance for failures;
2. Capacity to take on and mitigate risk, or ability to avoid risk;
3. Our policies, objectives, business plans and respective stakeholder demands;
4. Evolving industry, market, and other macro or micro environmental conditions.
TM Steels uses a Risk & Opportunity Register to help record, assess, respond, review, report, monitor and plan for
the risks and opportunities that we perceive to be relevant. The register allows our organisation to methodically
assess each risk and to study each opportunity associated with our organisational context, strategy, legal
requirements and compliance obligations that relate to the needs and expectations of our customers and
interested parties. The register records the control method for each risk and how each opportunity is exploited.
In order to preserve this knowledge, risk registers are retained as documented information.

Document Ref. TMS-IMS01 Page 16 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Supporting documentation:
Ref. Title & Description
02 Risks & Opportunities Procedure

6.1.2 Environmental Aspects

TM Steels identifies relevant environmental
Figure 5: Types of Environmental Aspect
aspects and their subsequent impacts that
pertain to our business operations, obligations
and customer requirements. Environmental
Energy
aspects and impacts are recorded within the usage
Aspect Identification & Assessment.
For each identified aspect, the operating
Production
conditions, environmental impacts and Recyling &
of waste &
disposal
perceived significance are summarised emissions
without the need to provide an exhaustive list of
all activities where there are several generic Environmental
and specialist impacts. Aspects
Within the register, an assessment of the
potential environmental impact of each aspect Purchased
Fuel used in
is undertaken and recorded, along with related raw
transport
materials
targets and objectives. A scoring system is
used to identify the significance of each
environmental aspect with regards to relevant
Water usage
current and past activities, products, services
and planned or new system or process
developments.
The scoring process allows consideration of normal, abnormal and emergency operating conditions where
applicable. The risks and opportunities encountered during the life cycle of our environmental aspects are
considered when determining the significance of each impact. Within the register, the environmental aspects are
sorted into six categories to facilitate their management and mitigation:
1. Use of natural resources;
2. Land development and buildings;
3. Pollution prevention;
4. Sustainable procurement;
5. Waste management;
6. Travel and transport.
This process is communicated using the Aspect Identification & Assessment Procedure. The subsequent output
from this process takes account of the severity of pertinent environmental aspects and our organisation’s ability
to influence them, in order to determine key issues and requirements that pose adverse or beneficial effects in a
prioritised way to:
1. Assure that the management system can achieve its intended outcomes;
2. Prevent or reduce undesired effects;
3. Achieve continual improvement.
Environmental aspects that we address include:

Document Ref. TMS-IMS01 Page 17 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

1. Those with significant environmental aspects;

2. Those that affect compliance with our obligations;
3. Those which are priority issues for the organisation (e.g. affect policies or objectives).
Environmental aspects which pose a significant impact are subject to risk management, corrective action, and
monitoring and measurement as appropriate. The EHQMS is structured to identify and manage these aspects in
order to control or limit potential impacts and risks that may affect our organisation and system conformity.
The significance of our organisation’s aspects is reviewed annually, including proposals for new processes,
services or developments and environmental aspects arising are also considered and assessed for significance
by the General Manager. New aspects are added to the Aspect Identification & Assessment as necessary and
operational control is altered accordingly.
Supporting documentation:
Ref. Title & Description
03 Aspect Identification & Assessment Procedure

6.1.3 Hazard Identification & Assessment

TM Steels has established and implemented a system to identify and assess occupational health and safety
hazards and to determine appropriate operational controls, Refer to 8.1.3. This activity is managed using the
Hazard Identification & Assessment Procedure. OHS hazards and risks are recorded within the Hazard
Identification Register.
The subsequent output from this activity takes account of the severity of pertinent occupational health and safety
hazards, the risk that they pose, as well as our ability to influence them. The health and safety hazards which give
rise to risk are subject to mitigation, corrective action, and monitoring, as appropriate. The following types of
activities and hazards are risk assessed prior starting work:
1. Routine and non-routine activities;
2. Hazards originating externally to the workplace;
3. Work operations including contractor activities;
4. Use of infrastructure, equipment and materials;
5. Whenever change occurs to systems, processes equipment, workers and contractors, materials etc.;
6. Changes in legislation;
7. Emergency situations and potential incidents e.g. fire, accidents;
8. Contractors and visitors to the workplace;
9. The capabilities of workers and contractors including human behavior.
Our organisation uses the Health & Safety Risk Assessment form for undertaking risk assessments of activities
that apply to our operations, customer requirements, and routine and non-routine activities. The risk controls
documented within the risk assessments are categorized into mandatory and additional controls. Risk
assessments are completed by the General Manager. Continuous systematic and formal monitoring of
implementation of the health and safety assessment process and outputs take place against appropriate
performance indicators to ensure process compliance and effectiveness.
Supporting documentation:
Ref. Title & Description
04 Hazard Identification & Assessment Procedure

6.1.4 Compliance & Legal Requirements

Document Ref. TMS-IMS01 Page 18 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Top management and the General Manager review all relevant environmental legislation directly related to our
identified environmental aspects and impacts using the NET-Regs service www.netregs.gov.uk which is service
provided by the UK Environment Agency. Applicable environmental aspects are identified, evaluated and
understood in terms of current legislation and their impact on customer requirements, include as appropriate:
1. The Climate Change Act 2008;
2. The Energy Performance of Buildings (England and Wales) Regulations 2012;
3. The Renewable Heat Incentive Scheme Regulations 2011;
4. Water Resources Act 1991;
5. Building Regulations 2000;
6. CRC Energy Efficiency Commitment Scheme;
7. Climate Change Levy Regulations.
All relevant legislation and other requirements applicable to TM Steels’ environmental aspects and impacts are
compiled into the Legal & Compliance Register. The General Manager ensures that applicable environmental
aspects are identified and understood in terms of customer requirements and current legislation.
Similarly, the General Manager reviews all relevant occupational health and safety related legal requirements,
regulations and Approved Codes of Practice (ACoPs) using the Health and Safety Executive’s website
www.hse.gov.uk/guidance/index.htm and ensures that all applicable occupational health and safety hazards are
identified, evaluated and understood in terms of current legislation, including as appropriate:
1. The Regulatory Reform (Fire Safety) Order 2005;
2. Reporting Hazards and Dangerous Conditions or Incidents (Near Misses);
3. Health and Safety (First Aid) Regulations 1981;
4. COSHH Regulations 2002;
5. Health and Safety at Work Act 1974;
6. The Safety Representatives and Safety Committees Regulations 1977;
7. The Health and Safety (Consultation with Employees) Regulations 1996.
It is the responsibility of the General Manager to maintain, review and update the Legal & Compliance Register, in
order to:
1. Determine whether legislation, amended, current or new legislation is ‘relevant’ or ‘irrelevant’;
2. Determine whether our organisation is compliant with the legislation;
3. Describe how the requirements apply and what controls are in place;
4. Determine other relevant compliance obligations and those that we should adopt;
5. Describe how the requirements apply to and what controls are in place to remain compliant;
6. Update and communicate the compliance obligations register to relevant staff;
7. Maintain records or periodic compliance reviews.
Legal and compliance obligations are reviewed on a regular basis with assistance from the automatic emails
received from NET-Regs whenever legislation is updated or is newly published. The process by which we manage
our compliance obligations and legal requirements is communicated using the Legal & Compliance Requirements
Procedure.

Supporting documentation:
Ref. Title & Description
05 Legal & Compliance Requirements Procedure

Document Ref. TMS-IMS01 Page 19 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

6.1.5 Planning Action

Our management system is planned and implemented in order to meet our corporate objectives and as such the
planning process involves establishing and communicating our corporate policies, objectives and associated
operational procedures.
This document constitutes our overall plan for establishing, maintaining and improving our QEHS management
system. For each instance of management system planning, the output is documented and retained accordingly.
Any changes are conducted in a controlled manner.
All identified significant environmental aspects and OHS hazards, and associated risks and opportunities that
need to be addressed, are used to prioritise action our action planning in order to manage and mitigate them. The
General Manager analyses the risks associated with each change and presents the assessment to Top
management for consideration.
The management review process, change control process, and the internal audit process ensure that the integrity
of our management system is maintained when significant changes affect key processes. The management
review makes recommendations to ensure that risks and opportunities that could affect the intended outcomes
of the management system are taken into account and planned for via the most appropriate business processes.

Management System Objectives

6.2.1 Integrated Objectives
TM Steels sets out its objectives and targets on a regular basis within the management review minutes where
details of programme dates and responsibilities are defined. Improvements in quality, occupational health and
safety, and environmental performance are incremental and are in keeping with the size and complexity of our
organisation. The process for determining our objectives is communicated by the Objectives, Targets & KPIs
Procedure. Each measurable objective:
1. Is consistent with our established strategies, policies and context;
2. Contributes to the prevention of accidents and incidents and to reduce their impact(s);
3. Contributes to the prevention of pollution;
4. Provides a basis for continual improvement;
5. Enhances customer satisfaction.
Objectives are set in association with the General Manager which are based on reported compliance levels,
audited deficiencies and legislative requirements, and agreed by the Top management. The General Manager
monitors and reports progress at monthly management meetings. To enable objectives and targets to be met,
annual improvement plans are developed, documented and integrated into our overall business planning process
and which:
1. Specifies the required resources (both human and financial) needed to meet the objectives;
2. Specifies the roles and responsibilities for implementing improvement plans and actions;
3. Establishes the timeframes for completion of improvement plans and achievement of objectives.
When setting objectives and targets, Top management ensures that they are consistent with the needs and
expectations of our interested parties, as defined in Section 4.2, and with our corporate targets and policies. In
addition, technological options, financial, operational and business requirements are considered.
Progress is reviewed routinely by Top management as part of the management review and reporting activities,
and incorporates any proposed developments for modified activities, products or services. Management
programmes are modified to account for any changes that affect the achievement of our objectives and targets.
All proceedings and decisions are recorded in the management review meeting minutes.

Document Ref. TMS-IMS01 Page 20 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

In order to determine whether or not our objectives and targets are being met, their related metrics are reported
visually as a set of key performance indicators (KPIs). This allows progress over time to be monitored as the
metrics are gathered and the data is analyzed. KPIs and objectives for our organisation include the following:
1. Turnover and profitability;
2. Sales targets and production efficiency targets:
3. Reject and rework and cost of quality targets;
4. Energy and raw material use targets;
5. Accident and incident frequency rate;
6. Staffing breakdown.
On the basis of our policies, TM Steels sets objectives that are specified in the Register of QEHS Objectives & KPIs.
All employees are aware of and, responsible, for the fulfillment of our policies and their subsequent objectives.
Managers of all departments are obliged to develop high level objectives into objectives applicable to their
departments and employees.

Objective Target Measure

Implement ISO 9001:2015 Maintain certification ISO 9001:2015 certificate
Implement ISO 14001:2015 Achieve certification by Q4 2024 ISO 14001:2015 certificate
Implement ISO 45001:2018 Achieve certification by Q4 2024 ISO 45001:2018 certificate
Implement training programme All employees trained by Q4 2024 Feedback, improved performance
Reduce wastage, increase recycling Increase recycling by 20% by Q4 2025 Reduced waste to landfill

6.2.2 Objectives & Planning to Achieve Them

Top Management are responsible for developing the Objectives Management Programme and targets for the whole
organisation. The General Manager is responsible for monitoring progress against our targets and objectives, and
for reporting this data to Top management. The identified significant environmental aspects, occupational health
and safety hazards, and quality risks and opportunities are used to prioritise which objectives and plans to
implement.
Top management is responsible for agreeing objectives and targets relating to activities under their control and
for approving and endorsing objectives and targets for the organisation. Planning for action to mitigate adverse
risk and significant impacts and the leveraging of opportunities is implemented via:
1. Management system objectives;
2. Monitoring, measuring and analysis;
3. Operational controls;
4. Emergency preparedness and incident response;
5. Others, as appropriate.
The programme acts as our management action plan that identifies individual objectives, the means by which the
objectives are to be achieved, and the timeframe in which the actions are to be achieved. Actions are assigned to
suitably authorized and competent employees, who are responsible for ensuring that the actions are completed
within the terms specified by the programme.
Our plans are driven by the identified significant environmental impacts, occupational health and safety hazards,
and the associated impacts, risks and opportunities. Regular and documented management reviews make
recommendations to ensure that those risks and opportunities and significant impacts that could affect the
intended outcomes of the management system are taken into account and planned for via the most appropriate
business processes.

Document Ref. TMS-IMS01 Page 21 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Reviews of progress towards the achievement of our objectives and targets, along with the status of the
implementation of improvement plans is conducted at regular and planned intervals or whenever there is a change
to activities, operating conditions, or product quality.

Supporting documentation:
Ref. Title & Description
06 Objectives, Targets & KPIs Procedure

Planning for Change

Management system reviews and planning activities are performed, prior to the implementation of any significant
changes that might impact upon the effectiveness of our integrated management system, in order to minimise
adverse effects, as necessary. These types of change may be:
1. Planned or unplanned;
2. Sudden or gradual;
3. Temporary or permanent.
The General Manager in conjunction with relevant process owners identify relevant risks and opportunities in
order to assess the potential impact of each change to current process practices and activities that might impact
upon the performance of the management system. Change assessments are presented to Top management for
consideration and approval.
The required changes are discussed and documented in the Management Review Minutes and subsequent audit
and inspection reports assure integrity of the management system and the availability of resources. The
allocation or reallocation of responsibilities and authorities is also discussed and documented during the
management review meeting.
Operational activities are also a source of change. The change process also applies to the following activities and
information which may foreseeably undergo change that require re-assessment after each change:

Type of change Related Section

Workplace locations and surroundings 4.1, 7.1.4
Working conditions 4.1, 7.1.4
Workforce, plant and equipment 4.1, 7.1.3, 7.1.4
Materials used, their composition and properties 8.2.3, 8.3, 8.4
Feedstock used and by-products/wastes generated 8.2.3, 8.3, 8.4
Drawings and engineered processes 7.1.6, 7.5, 8.1
Operating and maintenance procedures 7.1.3, 7.5, 8.1
Emergency procedures or changes to business resilience 4.1, 8.1, 8.8
Electronic system software 7.1.5
Organisational structures and responsibilities 4.1, 4.4, 5.3, 5.4, 7.1.2
Personnel changes, training or competency requirements 5.3, 5.4, 7.1.2, 7.2, 7.3
Individual roles and responsibilities 5.3, 5.4
Regulatory and statutory requirements 4.1, 6.1.4, 9.1
Changes in knowledge or information relating to OH&S risks 5.4, 6.1.3, 6.1.4, 7.1.6
New technology and processes 4.4, 6.1
Activities, products and services 4.1, 4.2, 4.3, 4.4, 8.1

Document Ref. TMS-IMS01 Page 22 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

The planning activities associated with these types of change are documented using OH&S hazard assessments,
workplace assessments, environmental aspect registers, compliance and legal requirements registers, and other
planning documents as appropriate.

Document Ref. TMS-IMS01 Page 23 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

7 Support
Resources
7.1.1 General
The resource requirements for the implementation, management, control and continual improvement of our IMS,
and the activities necessary to enhance customer satisfaction, are defined in our operational procedures, work
instructions and the following sections of this integrated management system manual:
1. Planning; Section 6.0
2. Management review; Section 9.3
3. Human resources; Section 7.1.2
4. Infrastructure; Section 7.1.3
5. Work environment; Section 7.1.4
6. Planning operational control; Section 8.1
7. Determination of customer requirements; Section 8.2

7.1.2 People
To ensure competence of our workers and contractors, the General Manager uses job specifications and
descriptions which identify the qualifications, experience and responsibilities that are required for each position
that affects product and management system conformity.
The General Manager reviews employee qualifications prior to hire when an employee changes positions or the
requirements for a position change. Qualifications include desired requirements for education, skills and
experience. Appropriate qualifications, along with the provision of any required training, provide the competence
required for each position.
The General Manager maintains records of employee qualifications. If any differences between the employee’s
qualifications and the requirements for the job are found, training or other action is taken to provide the employee
with the necessary competence. The results of training are evaluated for effectiveness.

7.1.3 Infrastructure & Natural Resources

Top management is responsible for planning, providing and maintaining the infrastructure and resources needed
to achieve product and process conformance, including buildings, workspace and associated utilities; process
equipment (hardware and software); and supporting services (such as internal transportation, material handling
systems, and communications systems).
The General Manager, supported by the Management team, has overall responsibility for managing the related
environmental impacts and occupational health and safety hazards present at our facilities or which exist
intrinsically within our equipment and process, or maintenance programmes, including:
1. Transportation and material handling;
2. Equipment management, maintenance and repair;
3. Process and production equipment management, maintenance and repair;
4. Facilities management, maintenance and repair.
The General Manager in conjunction with the Management Team have overall responsibility for managing and
mitigating our organisation’s use of natural resources (non-renewable electricity, natural gas, and water) which is
identified and managed as a significant environmental aspect, and to ensure that our operations remain
compliant with relevant parts of:
1. Our corporate policies and objectives;
2. Business and strategy planning;

Document Ref. TMS-IMS01 Page 24 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

3. Local Authority conditions;

4. Compliance obligations and legal requirements:
The operation and maintenance of plant and equipment that have the potential to impact management system
performance, as defined through risk analysis, is maintained, inspected and tested to ensure it meets design
descriptions and specifications. Documentation for critical processes, plant, and equipment is retained and made
available, and includes as applicable:
1. Codes and relevant legislation;
2. Hazard assessment reports;
3. Operating procedures and operating criteria;
4. Engineering drawings, specifications and engineering standards;
5. Maintenance, inspection and testing strategies;
6. The characteristics of the product or materials essential for safe and proper use.
Supporting documentation:
Ref. Title & Description
07 Infrastructure & Natural Resources

7.1.4 Operational Environment

TM Steels ensures that our offices and warehouses comply with relevant health and safety regulations. The
General Manager carries out regular compliance audits to ensure that appropriate standards are maintained. Top
management is committed to providing:
1. A place of work that is safe, including all equipment and methods of work;
2. Training, instruction, information and supervision for employees;
3. A means of safe handling, storage, use and transportation of equipment, materials and chemicals;
4. Safe working environment with good lighting, ventilation, safe passageways, stairs and corridors.
Where the work environment or the impact of workers and contractors on operational process is determined to
result in a risk to products or processes, then risk control measures are defined, documented and implemented.
The effectiveness of risk control measures is periodically assessed.

7.1.5 Monitoring & Measurement Tools

The General Manager determines the frequency of monitoring and measuring activities as well as the types of
tools and devices we use to provide evidence of valid measurements to verify specified tolerances and
measurement ranges. The frequency of maintenance and calibration is considered with reference to the risks
associated with the failure of the device upon the process and its output. The methodology for controlling
monitoring and measuring tools is communicated by the Calibrated Equipment Procedure. Where necessary, to
ensure the validity of results, calibrated equipment is:
1. Calibrated or verified at specified intervals, or prior to use;
2. Calibrated against measurement standards traceable to appropriate measurement standards;
3. Software used for monitoring and measurement is validated using defined parameters prior to use;
4. Protected from damage and deterioration during handling, maintenance and storage;
5. Safeguarded from adjustments that would invalidate the measurement result;
6. Identified to enable the unit’s calibration status to be determined;
7. Safeguarded from use when a unit is found to be out of calibration and the results revalidated;
8. Adjusted or re-adjusted as necessary.

Document Ref. TMS-IMS01 Page 25 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

In addition, the General Manager re-assesses and records the validity of previous measurement results when a
tool or device is subsequently found not to conform to requirements. The General Manager takes appropriate
action on any equipment, product or process that may be affected.
Where equipment is found to be out of calibration, the significance of the error is reviewed, its extent is traced
and the results are re-verified. Records of the results of calibration and validation are maintained using the
Controlled Equipment Log, the Calibration Log, and the Software Validation Log as documented information.

Supporting documentation:
Ref. Title & Description
08 Calibrated Equipment Procedure

7.1.6 Organisational Knowledge

TM Steels recognises that organisational knowledge is a valuable resource that supports our processes and
activities and which helps to assure the conformity of our products, processes, and services. There is a strong
link between organisational knowledge and the competence of our people, the latter being our employees’ ability
to apply knowledge to their work. We define organisational knowledge as information combined with experience,
context, interpretation, and insights that are useful when making decisions and taking action specific to our
management system.
To ensure that organisational knowledge relating to quality, environmental and OH&S aspects are captured and
disseminated through formal modes of training and communication. Organisational knowledge is captured in
documented information and is embedded into our processes, products and services. Examples of organisational
knowledge include:
1. Documented information regarding a process, product or service;
2. Previous specifications and work instructions;
3. The experience of skilled people operating their processes;
4. Mentoring and coaching by more experienced employees;
5. Knowledge or information relating to OH&S risks;
6. knowledge or information relating to environmental aspects;
7. Knowledge of new technologies and infrastructure relevant to our organisation, etc.
Sources of internal knowledge also include our intellectual property; knowledge gained from experience and
coaching; lessons learnt from failures and successes; capturing and sharing undocumented knowledge and
experience; the results of improvements in processes, products and services. TM Steels assimilates and deploys
internal and external sources of knowledge, such as:
1. Lessons learnt from non-conformities, corrective actions, and the results of improvement;
2. Gathering knowledge from customers, suppliers and partners
3. Benchmarking against competitors;
4. Capturing knowledge existing within the organisation, e.g. through mentoring/succession planning;
5. Sharing knowledge with relevant interested parties to ensure sustainability of the organisation.
6. Knowledge from conferences, attending trade fairs, networking seminars, or other external events
Sources of external knowledge often include other ISO standards; research papers; webinars from conferences;
or knowledge gathered from, or about; our customers, stakeholders or other external parties.

Competence
Top management identifies emerging competency needs during management reviews and annual appraisals.
Emergent competency needs are converted into job descriptions for the type and number of positions that need
to be filled through internal or external recruitment.

Document Ref. TMS-IMS01 Page 26 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

To ensure competence of our workers and contractors, job descriptions have been prepared identifying the
qualifications, experience and responsibilities that are required for each position that affects product and system
conformity. Qualifications include desired requirements for education, skills and experience. Appropriate
qualifications, along with the provision of any required training, provide the competence required for each
position.
Qualifications are reviewed upon hire, when an employee changes positions or the requirements for a position
change. The General Manager maintains records of employee qualifications. If any differences between the
employee’s qualifications and the requirements for the job are found, training or other action is taken to provide
the employee with the necessary competence. The results of training are evaluated to determine if it was
effective.
Staff training records are maintained to demonstrate competency and experience. The General Manager
maintains and reviews the training records to ensure completeness and to identify possible future training needs.
Training records are maintained and include as a minimum; copies of certificates for any training undertaken to
date, current job description and any other supporting documentation.
Where required; competency training and monitoring is conducted in-house, although for more specialist skills,
external seminars or courses are utilised. The effectiveness of training is evaluated and recorded. The company
induction includes an introduction to our policies and objectives. Future competency training needs are identified
as part of the management review process by reviewing the Competency Review Forms. As a minimum, the
following competency-based training is provided:
1. OH&S hazard identification and assessment (as appropriate to the role);
2. Operational controls (including procedures and/or work instructions);
3. Work place and safety and environmental monitoring;
4. Incident management (including investigation methods as appropriate to the role);
5. Process interactions.

Awareness
TM Steels operates a formal system to ensure that all employees within the organisation are adequately trained
and aware to enable them to perform their assigned duties. Those staff whose work is directly related to achieving
our organisation’s objectives; understand their particular responsibilities and accountabilities within the context
of the management system.
All employees are trained on the relevance and importance of their activities, and on how they contribute to the
achievement of our policies and objectives through their work. We aim to raise quality, environmental, and
occupational health and safety awareness by encouraging involvement with relevant schemes or initiatives.
All staff, whose work directly affects our organisation’s environmental impacts, or whom are exposed to health
and safety hazards, are briefed to ensure they understand their particular responsibilities and accountabilities
within the context of the management system.
Where required, awareness training is conducted in-house to allow the transfer of organisational knowledge but
for more specialist skills, external seminars, trainers or courses are utilised. The company induction includes an
introduction to our organisation’s policy statements and objectives. Future training needs are identified as part
of the management review process.
Employees are also encouraged to undertake personal and professional development with plans reviewed on an
annual basis at individual annual performance appraisals undertaken by line management. It is a requirement for
line managers to refer to the training needs analysis during this appraisal to identify any gaps and/or any refresher
training which may be due.

Document Ref. TMS-IMS01 Page 27 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

These are added to the personal and professional development plans for the following year. As a minimum, the
following awareness training is provided:
1. Understanding of our policies, the management system and its processes
2. Awareness of HSE standards & ACOPs;
3. Significant risks, aspects, impacts, hazards and activities;
4. Accountabilities of specific roles and responsibilities;
5. Consequences of departure from specified procedures or standards;
6. Emergency response procedures and business resilience.
Supporting documentation:
Ref. Title & Description
09 Competence & Awareness Procedure

Communication
7.4.1 General
TM Steels communicates information internally regarding the management system and its effectiveness, through
documented training, internal audit reports and continual improvement processes. All managers and supervisors
are responsible for establishing regular formal and informal communications as needed to convey to their
employees the relevance and importance of their activities; typically, this information is conveyed through team
meetings and cross-functional improvement projects.

7.4.2 Internal Communication

Communications regarding how employees contribute to the achievement of objectives are also conveyed and
reinforced during employee performance reviews. Issues pertaining to our IMS that may be communicated
internally include:
1. Day-to-day operations and general awareness;
2. Quality, environmental and health and safety policy;
3. Information on achieving objectives and targets;
4. Risk and opportunities.
Top management and their direct reports are responsible for communicating the corporate policies as well as the
importance of meeting customer, statutory and regulatory requirements to employees within their respective
departments.
They ensure that our policies and objectives are understood and applied to the daily work of the organisation
through the establishment of measurable goals and objectives. Internal communication occurs on an on-going
basis and is achieved through various mechanisms as appropriate:
1. Regular meetings and briefings;
2. Training sessions and training material;
3. Display boards, memorandums, letters;
4. Website, intranet, internal e-mails;
5. Product and process performance data analysis and audit results;
6. Targets, objectives, scorecards, KPIs, management system manual and procedures;
7. Corrective action and non-conformance reports.

7.4.3 External Communication

TM Steels determines the need to communicate information externally to our interested parties, as defined in
Section 4.2, regarding the effectives of our management system. In most instances, external interested parties
(such as consumers, stockholders, neighbouring communities, etc.) are the main driving force for our

Document Ref. TMS-IMS01 Page 28 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

organisation to implement our management system. The various processes or means of external communication
may include as appropriate:

Interested Parties Needs & Expectations Possible modes of Communication

Customers Price, reliability & value Publications in the media and focus groups
Distributors & retailers Price & logistics Industry association publications and press releases
Owners/Trustees Profitability & growth Annual reports or newsletters of performance
Suppliers Beneficial relationships Publications via website, meetings or questionnaires
General Public Environmental responsibility IMS visibility via company website
Health & Safety Executive Health and safety responsibility Compliance submissions, audit results and AFRs
Environment Agency Environmental responsibility Compliance submissions and audit results

TM Steels ensures that all external communications are authorized prior to release. Where required, advice
appropriate to the context of the communication may be sought concerning the content and dissemination of
certain external communications.
1. Internet - Information about our IMS is communicated externally via our website.
2. Enquiries – TM Steels is subject to the Freedom of Information Act and GDPR which requires a response
to external requests for information within specific timescales.
3. Social Media – TM Steels manages a LinkedIn account to share information, encourage behavioural
change and promote events. Similarly, TM Steels utilises an official Facebook page.
All social media is coordinated by our Sales Director. Responses to external communications are recorded if they
are transmitted by email or letter. In each case the response is retained and controlled in accordance with the
requirements for documented information.
Supporting documentation:
Ref. Title & Description
10 Communication & Participation Procedure

Documented Information
7.5.1 Management System Documents
TM Steels ensures that our management system includes the documented information required to be maintained
and retained by ISO 9001:2015, ISO 14001:2015, ISO 45001:2018, and additionally; any documented information
identified by our organisation that demonstrates effective operation. Refer to the Master Document Index on the
TM System.
TM Steels applies the following criteria to all types of documented information in order to assess whether the
information is necessary for demonstrating the effectiveness of our IMS, and whether it should be formally
controlled. Should any of the criteria apply, TM Steels ensures that this information is retained and/or maintained
as a form of 'documented information'.
1. Communicates a message internally or externally;
2. Provides evidence of process and product conformity;
3. Provides evidence that planned outputs were achieved;
4. Provides knowledge sharing.
Should any of the above criteria apply, TM Steels ensures that this information is retained and/or maintained as a
form of 'documented information' and preserved as organisational knowledge. See 7.1.6.

Document Ref. TMS-IMS01 Page 29 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

7.5.2 Creating & Updating

TM Steels ensures that when we create documented information it is appropriately identified and described (e.g.
title, date, author, reference number) and is available in an appropriate format (e.g. language, software version,
graphics, etc.) and on appropriate media (e.g. paper, electronic).
All documented information is reviewed and approved for suitability and adequacy. Where permanent changes to
a document are required, a request is made to document owner to consideration and implementation.

7.5.3 Controlling Documented Information

Documented information is retained to provide evidence of conformity to the requirements specified by ISO
standards, customer requirements and of the effective operation of our integrated management system.
TM Steels uses standard forms and templates that are accessed via the “Documents” tab on the TM computer
system. An electronic document management system, which is backed up and updated as required, is used to
retain documented information ensuring only the current versions are available to users. All management system
documents are controlled and communicated according to the Documented Information Procedure which defines
the process for:
1. Approving documents for adequacy prior to issue;
2. Reviewing and revising as necessary and re-approving documents;
3. Ensuring that changes and current revision status of documents are identified;
4. Ensuring that relevant versions of applicable documents are available at points of use;
5. Ensuring that documents remain legible and readily identifiable;
6. Ensuring that documents of external origin are identified and their distribution controlled;
7. Preventing the unintended use of obsolete documents;
8. Ensuring that documents of external origin are identified and their distribution controlled.
Supporting documentation:
Ref. Title & Description
11 Documented Information Procedure

Document Ref. TMS-IMS01 Page 30 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

8 Operation
Operational Planning & Control
8.1.1 Quality Operational Planning & Control
TM Steels establishes and implements documented plans and procedures that describe the processes identified
in Section 4.4 and the controls required for the provision of products and services in parallel with our objectives,
the potential for planned or unintended change, and the risks and opportunities identified in Section 6.1.1. During
the planning phase, Top management, the General Manager and other responsible personnel identify the following
parameters:
1. Objectives and requirements for the product or service;
2. Verification, validation, monitoring, inspection and test requirements;
3. Documented information to demonstrate conformity;
4. Related life cycle aspects, impacts and mitigations;
5. Documented information to demonstrate conformity;
6. Necessary resources; or outsourced processes and their controls;
7. Criteria for process performance and product/service acceptance;
8. Potential consequences and mitigation to change affecting input requirements;
9. Resources necessary to support the ongoing operation and maintenance of the product.
The output of this planning activity includes, as appropriate, documented plans, resource schedules, processes
and equipment requirements, procedures and design outputs.
Design and development activities targeted at controlling risks are supported by documented information. This
documentation relates the design activities to the identified risks in a way that provides objective evidence that
the nature and extent of the design control is reasonable and appropriate to the degree of risk.

8.1.2 Environmental Operational Planning & Control

TM Steels considers the environmental requirements and aspects that can be controlled and influenced during
each phase of the product life cycle. Where applicable, a life cycle approach is taken within our operational
controls so that the environmental impacts at each stage of the life-cycle are identified, assessed, and controlled,
or influenced. Refer to Figure 7 below.
By identifying and documenting information about the relevant environmental aspects (6.1.2) and compliance
obligations (6.1.4), we are able to prevent or mitigate adverse impacts during each life-cycle phase:
1. Procurement phase;
2. Manufacturing phase;
3. Packaging, transport and delivery phase;
4. Intended use;
5. End of life treatment and final disposal.
The relevant environmental management operational procedures are also applicable to outsourced processes
including those undertaken by contractors, the level and extent of control or influence is defined. The controls
identified do not absolve us of the responsibility to conform to client, statutory and regulatory requirements but
instead they enhance our capacity to effectively manage our supply chain.

Document Ref. TMS-IMS01 Page 31 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Figure 7 The Life-cycle & Environmental Requirements

Procurement
Environmental Contract Review Environmental
Phase
Requirements Requirements

Identify relevant
End-of-life environmental aspects Manufacturing
treatment & at each stage in the Phase
Final Disposal
products’ life cycle.

Significant Packaging Transport &

Intended Use Customer
Environmental Delivery Phase
Requirements
Impacts

Our organisation does not control or influence all of the activities of each outsourced process. Only those where
our organisation has responsibility for conforming to environmental requirements, in accordance with our
aspects, impacts and compliance obligations, are controlled or influenced.
TM Steels establishes and implements documented plans and procedures that describe the processes (Refer to
Section 4.3) and the controls required for the provision of products and services in cognizance to the objectives,
the potential for planned or unintended change, and the risks and opportunities identified in Section 6.1. During
this planning phase, management or other responsible personnel identify the following parameters:
1. Objectives and requirements for the product or service;
2. Verification, validation, monitoring, inspection and test requirements;
3. Documented information to demonstrate conformity;
4. Document information to demonstrate process effectiveness;
5. Necessary resources; or outsourced processes and their controls;
6. Criteria for process performance and product/service acceptance;
7. Potential consequences and mitigation to change affecting input requirements;
8. Resources necessary to support the ongoing operation and maintenance of the product.
The output of planning activity includes documented plans, resource schedules, processes, equipment
requirements, procedures and design outputs.

8.1.3 OH&S Operational Planning & Control

TM Steels has established and implemented a system to identify and assess occupational health and safety
hazards, refer to 6.1.3, and to implement the appropriate operational controls to mitigate the resulting risks.
Occupational health and safety procedures are implemented by all teams and departments using the appropriate
management system documentation to ensure that all activities, products and services meet the applicable
regulatory standards.
In terms of eliminating hazards and reducing OH&S risks that are presented during our operational activities, TM
Steels’ plans, implements, and controls processes for managing operational risks to the achievement of
applicable requirements, as appropriate to TM Steels’ and the product and services, by way of the:

Document Ref. TMS-IMS01 Page 32 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

1. Assignment of responsibilities for operational risk management;

2. Definition of risk assessment criteria (e.g., likelihood, consequences, risk acceptance);
3. Identification, assessment, and communication of risks throughout operations
4. Identification, implementation, and management of actions to mitigate risks that exceed the defined
risk acceptance criteria;
5. Acceptance of risks remaining after implementation of mitigating actions.
Where appropriate, aspects of product safety are controlled to assure safety during the entire product life cycle
as appropriate to the organisation and the product. Examples of these include:
1. Assessment of hazards and management of associated risks (see 6.1.3);
2. Management of safety critical items;
3. Analysis and reporting of occurred events affecting safety;
4. Communication of these events and training of affected workers and contractors.
Outsourced processes are controlled and influenced via purchasing and contractual agreements, documented
procedures, contracts, supplier agreements and other management system requirements, 2nd party audits, and
performance reviews as appropriate. Where applicable a life cycle approach is taken within the operational
controls so that the OHS hazards at each stage can be controlled or influenced.

Supporting documentation:
Ref. Title & Description
12 Operational Control Procedure

Determining Requirements for Products

8.2.1 Customer Communication
In accordance with our commitment to exceed our customers’ expectations, TM Steels highlights effective
customer communication as an essential element of delivering customer satisfaction. Appropriate handling of
customer communication helps to reduce customer dissatisfaction and, in many cases, turn a dissatisfying
scenario into a satisfying experience. Customer communication occurs through the following formats, events and
processes:
1. Brochures, specifications or technical data sheets relating to our products and services;
2. Enquiries, quotations and order forms, invoices and credit notes;
3. Confirmation of authorized orders and amended orders;
4. Delivery notes and certificates of conformity;
5. E-mails, letters and general correspondence;
6. When customer property is handled or controlled;
7. Customer feedback and complaints management process;
The Sales Director is responsible for establishing methods of communication with our customers and interested
parties to ensure that all enquiries, contracts or order handling; including amendments, customer feedback and
complaints are handled expeditiously and professionally.

8.2.2 Determining Requirements

TM Steels develops appropriate requirements to ensure that we satisfy the needs and expectations across the
socio-technical environment including those of our customers, stakeholders or relevant interested parties.
TM Steels ensures that customer requirements are clearly articulated and that their requirements are captured
and understood before the acceptance of an order. Customer requirements include the following:
1. Previous customer requirements which pertain to current parts being ordered;

Document Ref. TMS-IMS01 Page 33 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

2. Statutory and regulatory obligations related to the product’s lifecycle;

3. Customer specified performance requirements;
4. Any additional requirements will be determined by TM Steels.
5. Requirements not stated by the customer, but which are necessary for specified or intended use.
TM Steels controls the stages of the product lifecycle by establishing environmental requirements for each
product during its design and development phase. This is a customer-driven process that requires clear, and often
repeated, customer interaction to understand and confirm the customer’s needs.

8.2.3 Reviewing Requirements

Prior to committing to the customer, TM Steels ensures and confirms our capacity to supply the required product
or service. Pre-acceptance reviews are conducted to ensure that:
1. Product requirements are defined and appropriate;
2. Environmental, and health and safety requirements are defined and appropriate;
3. Requirements are defined for delivery and post-delivery activities such as product or service support;
4. Requirements not stated by the customer but which are necessary for intended use are appropriate;
5. Any additional requirements determined by TM Steels are appropriate;
6. Contract or order requirements differing from those previously expressed are resolved;
7. TM Steels has the ability to meet the defined requirements;
8. Documented information is retained to show the results of the review.
Customer requirements are confirmed before acceptance by the exchange of contracts or purchase orders via
appropriate electronic or hard copy formats.
Evidence of requirements review is documented using the Requirements Review Checklist.

8.2.4 Changes in Requirements

TM Steels ensures that all relevant documented information; relating to changes in product or service
requirements, are authorised and amended where necessary, and that all relevant personnel are made aware of
the documented changes to customer requirements.
In order to manage the risks associated with any change to business processes, the General Manager identifies
and assesses each change that may impact on performance.
Supporting documentation:
Ref. Title & Description
13 Contract Review Procedure

Design & Development

8.3.1 General
Design and Development is not applicable to the Scope of TM Steels’ Supply

Control of Suppliers, External Processes and Contractors

8.4.1 General
The purchasing process is essential to our organisation’s ability to provide our customers with products and
services that meet their requirements. TM Steels ensures that all purchased products, services and outsourced
processes that are incorporated into our final products, or which impact management system performance,
conform to specified quality, environmental and OH&S requirements.

Document Ref. TMS-IMS01 Page 34 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

TM Steels accomplishes control by closely working with a network of external suppliers, providers and
contractors. Their performance and capability are continually assessed through periodic, 2nd party audits,
performance data analysis, verification of the supplied products or services, and the inspection of the work of
contractors.
The type and extent of control applied to our contractors and suppliers are dependent upon the effect that the
supplied product or outsourced process or service may have on our final product output. The following
considerations are taken in to account by:
1. Ensuring that we understand the capabilities and competencies of potential suppliers and contractors;
2. Ensuring that we clearly communicate the roles and responsibilities to suppliers and contractors;
3. Defining the quality requirements for the outsourced process, activity, or product;
4. Establishing upfront the criteria for and review of deliverables, frequency of inspections, audits, and
other appropriate methods of validation;
5. Selecting and qualifying appropriate suppliers, outsourced process providers and contractors.
Potential product suppliers, process providers and contractors are evaluated using the Supplier Evaluation Form
and are added to the Approved Supplier Index after successful evaluation. The Purchasing Manager evaluates and
selects suppliers based on their ability to supply products or services in accordance with specified quality,
environmental, and occupational health and safety requirements. This approach helps to mitigate any identified
significant environmental aspects and OH&S hazards during procurement of goods and services and to ensure
that our procurement operations remain compliant with our:
1. Corporate policies and objectives;
2. Sustainable development procurement policy;
3. Register of environmental compliance obligations
4. OH&S legal requirements and other requirements;
5. Environmental aspects register;
6. Hazard identification and assessments.
Additionally, other internal resources may be called upon to assist as required. The criteria for the selection,
evaluation and re-evaluation are defined and communicated in the Purchasing & Procurement Procedure, while
records of the results of evaluations and any necessary actions arising from the evaluation are retained.

8.4.2 Purchasing Controls

TM Steels applies and documents quality, environmental and OH&S criteria to the selection of our suppliers and
contractors. The criteria are agreed and communicated via contractual documents.
TM Steels has established and implemented a process of incoming inspection to ensure that purchased products
conform to:
1. Purchase orders and delivery notes;
2. Product specifications;
3. National or international standards.
Purchased items and delivery notes are checked against the purchase order to confirm that the identity and
quantity are correct. The inspection is recorded on the Goods Received Note. Satisfactory items are placed in
stock. In the event that items are rejected on receipt, a non-conformance report is raised and the supplier
contacted to arrange replacement or credit.
Where appropriate, risk control measures are applied to outsourced process or products. Risk control measures,
and their importance, are documented within the purchasing data and clearly communicated to the supplier. The

Document Ref. TMS-IMS01 Page 35 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

frequency of contract reviews with each supplier varies depending on their performance at any time and the
interval between reviews varies from monthly to annually.
8.4.3 Purchasing Information
TM Steels uses purchase orders to describe the product or service to be purchased. Designated individuals within
the company create purchase orders using the company system. They also ensure the adequacy of the
requirements that are specified by the purchase order prior to release. Each purchase order includes where
appropriate:
1. Identification of product or service to be delivered, quantity, delivery date, and cost;
2. Requirements for approval or qualification of product, procedures, processes or equipment;
3. Requirements of the supplier’s management system
4. Competence of contractors;
5. Contractual requirements and operating criteria.
Where appropriate, the roles and responsibilities for risk management on the part of the manufacturer or supplier
are defined as part of the purchasing requirements. In addition, prescribed risk control measures are included in
the purchasing requirements as part of the purchasing information which clearly communicated to the supplier
or manufacturer.

Supporting documentation:
Ref. Title & Description
15 Purchasing & Procurement Procedure

Production & Service Provision

8.5.1 Control of Production & Service Provision
In order to control the planning, administrative support and implementation of work, our organisation’s policy is
to describe the work methods, the controls applied and the records required. The process control activities are
quality with many aspects that also relate to quality control. The following controlled conditions are applied where
applicable:
1. Quality control checks are performed using appropriate measuring equipment;
2. Handling, storage and transportation;
3. Evidence of completed inspections;
4. Detailed process work instructions and specifications for all products;
5. Criteria for workmanship, competence and plant maintenance.
In cases where special processes are employed where the results of which cannot be easily checked, including
any processes where deficiencies become apparent only after the product is in use. Validation demonstrates the
ability of these processes to achieve planned results by:
1. Defining qualification criteria and approval of special processes prior to use;
2. Defining criteria for review and approval of the processes;
3. Approval of equipment and qualification of workers and contractors;
4. Use of specific methods and procedures;
5. Requirements for records;
6. Revalidation.
Production information such as the rate of non-conformities, the rate of rework, scrap, yield, and other sources
of quality data are evaluated and or compared against the current risk management output to confirm adequacy
and completeness of risk controls.

Document Ref. TMS-IMS01 Page 36 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

8.5.2 Identification & Traceability

In order to preserve the conformance of products to customer requirements during internal processing and
delivery, TM Steels identifies the product throughout the product realisation process:
1. Stored equipment and materials are identified as to type, description and inspection status;
2. Unacceptable items are identified as such and are removed from the normal work flow;
3. All enquiries are identified with a unique estimate number, allocated on receipt;
4. Subsequent orders are identified by contract number.
Where appropriate, the General Manager has implemented an identification system allows for traceability from
finished product back to incoming material records and customer specifications. All parts, products and
materials, either purchased or manufactured, are identified with part numbers and or job numbers and where
applicable, serial numbers, which link the parts, products and materials to their respective documentation.
When required by the customer, traceability is maintained from receipt of parts to delivery of the final products.
The General Manager maintains records that trace part numbers to their corresponding drawings, specifications
and any other relevant documentation such as product configuration records that trace serial numbers of
products to their parts lists. Final product serial numbers are recorded on shipping documentation to provide
traceability to the end user (customer) and to the originating work order.

8.5.3 3rd Party Property

TM Steels identifies, verifies, protects and maintains customer property provided for use. The General Manager
ensures that lost, damaged or unsuitable customer property is recorded and immediately reported to the
customer. In cases where the customer provides drawings, specifications, etc., they are managed as documented
information. Customer property can also include customer-owned materials, tools (including packaging), tooling
(including test/inspection tooling and equipment), and intellectual property.
1. Unless otherwise defined by contract, upon receipt of customer property, our organisation will examine
items for completeness, proper identification and possible transit damage and identifies these items as
the property of the relevant customer;
2. Items found to be non-conforming are quarantined, tagged and recorded as defined in the Non-
conforming Output Procedure and brought to the immediate attention of the customer;
3. No customer property is released for further processing or storage until such time as all required
verification and testing activities are completed and the results are found to be acceptable;
4. After receipt, care is exercised to ensure the protection of customer property against loss or damage
until such time as it is incorporated into the product or returned to the customer;
5. The identification, segregation, handling, and protection of customer property from time of receipt,
subsequent storage, maintenance, during the entire realization cycle are performed in accordance with
Section 8.5.4 and any applicable contract requirements;
6. In the event that customer property is lost, damaged or otherwise identified as unsuitable for use while
under our control, these conditions shall be recorded and reported to the customer.

8.5.4 Preservation
TM Steels ensures that all products and materials are handled and stored appropriately at all stages of the
development cycle to prevent damage or deterioration. Products and materials are stored in designated storage
areas with appropriate control of inbound receipts and outbound releases.
Products in storage are periodically assessed. All packaging is sufficient to ensure product quality while in storage
and during delivery to the customer:
1. Components and products are handled and stored in a manner that prevents damage or deterioration,
pending use or delivery;
2. Controls are implemented to prevent mixing conforming and non-conforming materials;

Document Ref. TMS-IMS01 Page 37 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

3. Packing ensures specified or original manufacturing packaging is utilised;

4. All products are suitably packed to prevent deterioration or damage during storage and delivery.
Completed products awaiting packaging and shipping are protected to prevent damage from vibration, shock,
abrasion, corrosion, humidity, temperature, or any other conditions that may occur during handling or storage.

8.5.5 Post-delivery Activities

TM Steels determines the customer’s requirements for post-delivery activities before accepting an order. In
determining the extent of post-delivery activities that are required, we consider:
1. Statutory and regulatory requirements;
2. The potential undesired consequences associated with our products and services;
3. The nature, use and intended lifetime of our products and services;
4. Customer requirements;
5. Customer feedback.
Post-delivery activities also include as appropriate actions under warranty provisions, contractual obligations
such as maintenance services, and supplementary services such as recycling or final disposal.

8.5.6 Control of Changes

Changes to the production and service provision requirements are identified, communicated and recorded as
appropriate. Any unplanned changes are reviewed, verified, validated and approved to ensure that products and
services continue to meet their specified requirements, in such a way that conformity with requirements is
maintained. Changes are documented and information is retained about changes, including who authorized the
change, and the actions arising from the change.

Supporting documentation:
Ref. Title & Description
16 Product & Service Provision Procedure

Release of Products & Services

The extent and sequence of the required inspection and test are specified in documented procedures, work
instructions and manufacturing planning documents in order to demonstrate that the specified requirements are
met.
The amount and nature of inspection and test are based on the importance of the product characteristic, the
process control exercised and the specified requirements. All inspection and test activities are carried out by
competent, authorized workers. TM Steels uses the following methods as a means to ensure product acceptance.
1. Incoming inspection - Incoming material is withheld pending completion of required inspection or
receipt of objective evidence of conformance from the supplier;
2. First-article inspection and testing - Typically the first produced unit that both the customer or
supplier agree to use as the required base-line standard for all following units;
3. In-process inspection and testing - Products are withheld from further processing until there is
objective evidence that the required inspection and test have been performed;
4. Final inspection and testing - Evidence that all inspections and tests that were required during
previous stages of manufacturing were performed and documented as meeting the requirements.
Measurement and acceptance criteria that are necessary for product acceptance are retained as documented
information; subsequent acceptance records form the production documentation evidence which includes the
following information:
1. Criteria for acceptance and rejection;

Document Ref. TMS-IMS01 Page 38 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

2. Locations in the process sequence where measurement and testing operations were performed.
3. Types of measurement instruments used, including any instructions associated with their use.
4. Test records showing actual test results where required by the specification or acceptance test plan.
Documented information is retained to indicate the person authorising the release of the product. Product
release and service delivery does not proceed until all the planned arrangements have been satisfactorily
completed, unless otherwise approved by a relevant authority, and where applicable by the customer.

Supporting documentation:
Ref. Title & Description
17 Testing & Inspection Procedure

Non-conforming Outputs
TM Steels ensures that provisions are made for the identification and control of all non-conforming outputs and
materials including non-conforming product return by a customer, in order to prevent the inadvertent use or
shipment of non-conforming products and the unnecessary costs associated with the processing of non-
conforming products.
The Non-conforming Outputs Procedure defines the responsibilities, authorities and methods used for the
identification, segregation, review and disposition of non-conforming products, as well as the implementation of
corrective action in order to prevent recurrence of the non-conformance, and action appropriate to the effect, or
potential effects, of the non-conformity when non-conforming product is detected after delivery or use has
started.
Records, clearly identifying the product, the nature and extent of nonconformance, the approved disposition and
corrective action taken are maintained and as documented information in accordance with Section 7.5.
Disposition of ‘use-as-is’ or ‘rework’ is only used after approval by an authorised representative of the organisation
responsible for the design.
Documented information concerning the nature of any non-conformances, the resolving authority, and the
resulting corrective actions is retained. Where necessary, details concerning any authorized concessions are
documented as evidence of acceptance.
Supporting documentation:
Ref. Title & Description
18 Non-conforming Outputs Procedure

Emergency Situations
TM Steels has identified potential emergency situations pertaining to our business operations which may lead to
an undesired environmental impact or health and safety hazard. The General Manager in conjunction with the
Management Team are responsible for ensuring that procedures and practices are established for preventing and
responding to emergency situations.
The Emergency Management Plan is jointly owned by the General Manager with responsibilities assigned to a
dedicated Emergency Response Team, which includes trained Fire Marshals and 1st Aiders, and is periodically
tested by during regular drills. The Emergency Management Plan is initiated in the event of an emergency arising
from the following environmental hazards:
1. Flood, fire, natural disaster;
2. Accident, incident or near miss;
3. Release of chemical substances;

Document Ref. TMS-IMS01 Page 39 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

The Emergency Situations Procedure and related documents address the following:
1. Identification of potential and actual accidents and emergency situations;
2. Proper response to emergencies and prevention or mitigation of serious environmental impacts;
3. Provisions for periodic reviews and revisions of the procedures;
4. Such reviews are always initiated after the occurrence of such events;
5. Periodic drills to test the effectiveness of emergency preparedness and response procedures;
Records of environmental incidents, near-misses and non-conformities with IMS procedures are documented. In
the event of an incident, non-conformity, or near miss, members of staff involved or witnessing the incident are
responsible for reporting the event to the General Manager who is responsible for investigating the issue to
establish the root cause.
Supporting documentation:
Ref. Title & Description
19 Emergency Situations Procedure

Document Ref. TMS-IMS01 Page 40 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

9 Performance Evaluation
Monitoring, Measurement, Analysis & Evaluation
9.1.1 General
TM Steels applies suitable methods for determining which aspects of the IMS and its processes are to be
monitored, measured, analysed and evaluated. The frequency at which our processes are monitored, measured,
analyzed and evaluated is determined and informed by:
1. Statutory and regulatory requirements.
2. Customer feedback and specification requirements.
3. Process and management system requirements and the criticality for product conformity.
4. Process performance and audit results.
5. Level of risk and types of control measure.
6. Trends in non-conformities or corrective actions.
All monitoring, measuring, analysis and evaluation outputs are documented and analyzed to determine process
effectiveness and to ensure their effectiveness in achieving in-tolerance results, and to identify opportunities for
improvement:
1. In-process checks relate to both quality control and productivity checks;
2. Provision is made for the identification and resolution of non-conformances;
3. The emphasis is to prevent any problems which might affect customer satisfaction;
4. In-process checks are performed and documented;
5. Where specific inspection points are required these are identified at the contract planning phase.
Where applicable, all measurements, analyses, and test and inspection records are retained as documented
information for a minimum of three years. This documented information includes details of the final inspection
authority to confirm that all critical parameters are in accordance with the established requirements and
specifications. Additionally, product samples are stored and protected for five years.
Products are not normally released or delivered until all planned inspections and tests have been completed and
that documented information exists to provide evidence of conformity with acceptance criteria and which
identifies the person(s) authorizing release. In rare cases (due to customer requirements and/or production
emergencies) unverified product may be released or delivered under controlled conditions of positive recall, as
documented and approved by the customer or supplier.

9.1.2 Customer Satisfaction

The success in meeting our customer’s requirements and in achieving a high level of customer satisfaction with
TM Steels’ products and services is evaluated on a regular basis, at least annually. This is done using, but is not
limited to, on-time delivery performance, warranty analysis, in-service performance monitoring, customer
complaint analysis, annual customer satisfaction surveys, and other appropriate means. The customer
satisfaction results are summarized for discussion at management reviews.
TM Steels has developed and implemented plans for customer satisfaction improvement that address any
deficiencies identified by these evaluations and to assess the effectiveness of the results. TM Steels has
implemented a method of handling customer enquiries and is established to provide a rapid response to
customers who have an urgent need for assistance, or a complaint, which would adversely affect customer
satisfaction.

Document Ref. TMS-IMS01 Page 41 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Supporting documentation:
Ref. Title & Description
20 Customer Satisfaction Procedure

9.1.3 Analysis & Evaluation

In order to identify opportunities for improvement, Top management, General Manager and other managers, as
appropriate, routinely collect and analyse data using appropriate statistical and non-statistical techniques to
determine the suitability and effectiveness of key management system processes using data points applicable to
their area(s) of responsibility.
Effectiveness is measured in terms of product quality, environmental compliance, process accuracy, delivery
schedule performance, cost and budgetary performance, employee performance against established objectives
and levels of customer satisfaction. In order to identify ongoing strengths, weaknesses, threats and opportunities
within our integrated management system, TM Steels monitors and analyzes trends using the following data
points:
1. Characteristics of processes, products and their trends;
2. Conformity to product, customer, environmental and legal requirements;
3. Customer satisfaction and perception data;
4. Supplier and external provider performance data;
5. Results of actions taken to address risks and opportunities;
6. Effective implementation of integrated management system planning;
7. Improvement opportunities identified during internal audits and management reviews.
Control limits for process and product performance are expressed as objectives, and targets and are
disseminated via documented information as appropriate.
TM Steels undertakes corrective action when the data shows a trend toward the pre-defined control limit.
Employees, who utilize statistical tools to analyse; measure and verify outputs, are competent to ensure proper
deployment of these techniques.

9.1.4 Evaluation of Compliance

Conformance with current environmental and health and safety legislation is reviewed, and evidence of evaluation
is maintained through the management review process. In addition to monitoring and measurement of
operational activities, the General Manager periodically evaluates our compliance with all applicable legal
requirements, compliance obligations and other requirements to which we subscribe.
In most cases, monitoring and measurement is an on-going process intended to collect data required by legal and
other requirements. The evaluation of compliance analyzes and compares the data collected over a period of time
in comparison with our stated compliance obligations and legal requirements as defined in the Legal & Compliance
Register.

Supporting documentation:
Ref. Title & Description
21 Analysis & Evaluation Procedure

Internal Audit
9.2.1 General
Internal audit results are critical inputs that help to assess the effectiveness of our IMS. TM Steels’ internal audits
use risk-based thinking and the notion of continual improvement as the main drivers. Internal audits are

Document Ref. TMS-IMS01 Page 42 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

conducted at planned intervals to determine whether the management system conforms our organisation’s
planned arrangements and to the requirements of ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018.

9.2.2 Internal Audit Programme

The internal audit programme, coordinated by the General Manager, details the frequency and general focus of
each internal audit and is recorded and communicated within the Internal Audit Programme. TM Steels’ internal
audit programme is based upon a strategy that considers the status and importance of each process comprising
the scope of our IMS.
The audit frequency is also based upon process performance trends, results from previous audits, levels of
customer satisfaction, rates of non-conformity and corrective action, etc. to ensure that our organisation
focuses on the aspects that affect product and process conformity the most.
The criteria, scope, frequency and methods of each audit are defined in the audit reports. The selection of trained
auditors and their subsequent impartial conduct ensures objectivity throughout the audit process and that:
1. The results of each are reported to Top management;
2. That timely appropriate corrective action undertaken where required;
3. They retain documented information such as audit checklists and audit reports as evidence of the
effective implementation of the audit programme in respect of each audit.
Internal auditors are selected to ensure objectivity and impartiality of the audit process. This is achieved by
selecting a team of auditors from cross-functional departments who have received the appropriate training in the
auditing process.
The audit is conducted according to the Internal Audit Procedure to ensure that timely corrective actions are
implemented to correct any deficiencies found. The results of the audits are recorded and submitted to the
personnel having responsibility in the area audited. The results of the internal quality audits are summarized for
discussion at management reviews.

Supporting documentation:
Ref. Title & Description
22 Internal Audit Procedure

Management Review
9.3.1 General
To ensure the continuing suitability, adequacy and effectiveness of our IMS in meeting our organisation’s
strategies, Top management conducts formal management review meetings at planned internals. The
requirements for conducting management review are defined and communicated using the Management Review
Procedure.
In summary, a Director chairs the Management Review Meeting. The review group is coordinated and recorded by
the General Manager. To ensure that the review group includes each of the requirements of ISO 9001:2015, ISO
14001:2015 and ISO 45001:2018, the Management Review Agenda & Minutes are prepared and distributed by the
General Manager.

9.3.2 Inputs
The primary management review inputs comprise data from conformance and performance measurements that
are gathered at key quality, environmental, and health and safety data points from various processes and
activities. Subsequent reported recommendations for improvement are based on the evaluation of such
measurements.

Document Ref. TMS-IMS01 Page 43 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Conformance is primarily assured through internal audits and demonstrated through a review of audit results and
our demonstrated ability to detect, correct and to prevent problems. Performance is primarily assured through
the deployment of corporate and operational level objectives, and through the review of our demonstrated ability
to achieve desired results. The management review evaluates the need for change and to establish actions to
improve our IMS, its processes and resource needs. The management review is led by a director and considers
the following:
1. The suitability of our IMS policies;
2. The impact of changes in compliance obligations;
3. The management of risk and opportunity;
4. IMS objectives, targets and performance indicators;
5. Changing expectations and requirements of relevant interested parties;
6. Changes in the products or organisational activities;
7. Changes to the organisational structure;
8. Communication and feedback from employees and customers;
9. Change management effectiveness;
10. Workplace, environmental, and occupational health and safety monitoring;
11. The status of non-conformities and corrective actions;
12. Performance statistics, including summaries of safety statistics and environmental monitoring results.
13. Findings of completed audits and reviews;
14. Follow up on actions from previous management reviews;
15. Recommendations and opportunities for improving the effectiveness of the IMS.

9.3.3 Outputs
The primary outputs of management review meetings are management actions that are taken to make changes
or improvements to our quality management system. During management review meetings, Top management
identifies appropriate actions to be taken regarding the following issues:
1. Improvement of the effectiveness of the IMS and its processes;
2. Improvement of product related to customer requirements;
3. Opportunities and risks;
4. Significant environmental aspects;
5. Resource needs.
The primary outputs of management review meetings are the actions necessary to make changes or
improvements to our IMS. Responsibilities for required actions are assigned to members of the management
review team. Any decisions made during the meeting, assigned actions and their due dates are recorded in the
management review minutes. Management review minutes are retained and include:
1. Decisions and actions relating to possible changes to policies, objectives and targets;
2. Information relating to revised risks and any proposed treatment and controls;
3. Improvement suggestions for inclusion into future management plans;
4. Any other alternation, modification and improvement to the IMS that demonstrates a commitment to
continual improvement.
Relevant outputs from the management reviews are made available for communication and consultation
throughout our organisation.

Document Ref. TMS-IMS01 Page 44 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Supporting documentation:
Ref. Title & Description
23 Management Review Procedure

Document Ref. TMS-IMS01 Page 45 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

10 Improvement
General
The General Manager uses a range of the performance evaluation tools highlighted in Section 9 to make
recommendations for improvement and to achieve the intended outcomes of our IMS. For example,
recommendations may emerge from the review groups and from findings raised in internal audits.
In order to determine and select opportunities for improvement or to implement any necessary actions to meet
the requirements of customers and relevant interested parties, or to enhance customer satisfaction, TM Steels
drives improvement via the analysis of relevant data. The data inputs for the improvement process include:
1. Risk and opportunity evaluations;
2. Assessment of the changing needs and expectations of interested parties;
3. The conformity of existing products and services;
4. The effectiveness of our IMS;
5. Supplier performance;
6. Environmental performance;
7. Reducing or eliminating adverse environmental impacts;
8. Reducing or eliminating adverse OH&S hazards;
9. Increasing beneficial impacts and opportunities;
10. Levels of customer satisfaction, including complaints and feedback;
11. Internal and external audit results;
12. Corrective action and non-conformance rates;
13. Data from process and product characteristics and their trends.
TM Steels also ensures that opportunities for improvement from daily feedback on operational performance are
evaluated by the General Manager as appropriate. Changes are typically implemented through the corrective
action system. Opportunities for improvement from analysis of longer-term data and trends are evaluated and
implemented through the management review process and are prioritized with respect to their relevance for
achieving our quality and environmental objectives.
The overall effectiveness of continual improvement program (including corrective actions taken as well as the
overall progress towards achieving corporate level improvement objectives) is assessed through our
management review process.

Incident, Non-conformity & Corrective Action

10.2.1 Non-conformity & Corrective Action
All non-conformities are reported to the General Manager in order that an investigation can be initiated using the
Non-conformity & Corrective Action Procedure. The appropriate manager documents the non-conformity using
the Non-conformance Report and together with process owners, they consider the root-cause of the non-
conformity.
Where necessary, other competent parties are consulted to identify the root cause and plan appropriate action.
The General Manager records the non-conformance together with any agreed corrective action within the NCR
System.
The appropriateness and effectiveness of any corrective action is reviewed during documented reviews, and via
the internal audit process, and reported as necessary to Top management. Evidence of non-conformity, customer
dissatisfaction or process weakness is used to drive our continual improvement system. Since problems may

Document Ref. TMS-IMS01 Page 46 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

already exist, they require immediate correction and possible additional action aimed at eliminating or reducing
the likelihood of its recurrence.
Follow-up audits are conducted in accordance with the internal audit process to ensure that effective corrective
action is implemented and that the action is appropriate to the impact and nature of the problem encountered. In
addition, the General Manager summarises and analyses corrective action data to identify trends in order to
assess the overall effectiveness of the corrective action system and to develop related recommendations for
improvement.
The resulting corrective actions are reviewed by the General Manager for effectiveness and are reported to Top
management in order to determine if changes to the IMS are required, or whether any new risks or opportunities
need to be considered during planning.
The corrective actions are considered effective if the specific problem was corrected and subsequent data
indicates that the same or similar problems have not recurred. Results of data analysis and subsequent
recommendations are presented to Top management for review.

Supporting documentation:
Ref. Title & Description
24 Non-conformity & Corrective Action Procedure

10.2.2 Incident Investigation

TM Steels has implemented the Incident Investigation Procedure for the handling of, and the investigation of
accidents, incidents and near misses. The procedure defines the controls for reporting and investigating all types
of accident, incident or near miss that may occur on our premises.
By identifying the root cause and implementing relevant corrective actions, we aim to avoid reoccurrence.
Records are maintained of any changes to the documented procedures resulting from corrective action.
Records of occupational health and safety issues and non-conformities with the occupational health and safety
management procedures are documented. In the event of an accident, incident, or near miss; members of staff
involved or witnessing the incident are responsible for completing an Incident Report.
The report is sent to the General Manager who is responsible for investigating all accidents, incidents and near-
misses using the Incident Investigation Form, to establish the root cause.
Supporting documentation:
Ref. Title & Description
25 Incident Investigation Procedure

Improvement
TM Steels continually improves the effectiveness of our IMS through the effective application of our corporate
policies, objectives, auditing and data analysis, corrective and preventive actions, and management reviews.
The continual improvement process begins with the establishment of our corporate policies and objectives for
improvement, based on objectives contained in our business plans and customer targets and goals. Customer
satisfaction, internal audit data, process and product performance data, and the cost of poor quality or risk
control are compared against objectives or KPIs to identify additional opportunities for improvement.
The overall effectiveness of continual improvement program, including the effectiveness of any corrective
actions, as well as the overall progress towards achieving corporate level improvement objectives, are assessed
through our management review process.

Document Ref. TMS-IMS01 Page 47 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Supporting documentation:
Ref. Title & Description
26 Continual Improvement Procedure

Document Ref. TMS-IMS01 Page 48 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

Appendices
A.1 QEHS Process Interaction
Customers & Interested Parties

Management & Review Processes

Customer Requirements Customer Satisfaction

Strategic direction, Operational activities

operational purpose and product
and IMS Planning realization Customer Feedback
QEHS Planning
Strategic Planning Customer Perceptions
1. PLAN 2. DO Complaints
Production Planning
Process Planning Product Returns
Contract Review Performance Corrective Action
Corrective action
evaluation and
and improvement
management review

3. CHECK 4. ACT

QEHS Requirements QEHS Data Points

Policies, Objectives & KPIs Supplier Metrics

Risks & Opportunities Process Metrics
Competence & Awareness Product Metrics
Hazard/Aspect assessment Service Metrics
Responsibilities & Authority Non-conformances

Operation & Production Processes

A. New or
2. Produce 3. Contract 4. Order
1. Receive Order Existing
Quote Review Acceptance
Product?

Existing New

6. Amendment 7. Purchasing & 8. Receiving

B. Production
5. Specifications Control & Outsourcing Inspection, ID &
Processes
Validation Controls Traceability

Non-conforming

C. Non-
9. In-process 10. Final 11. Packaging &
12. Despatch conforming
Inspection Acceptance Product Storage
Outputs

Non-conforming

Support & Assurance Processes

Hazard & Calibration Internal Documents Data Root- Customers &

Aspect & Asset Audits & /Records & Analysis & cause Interested
Assessment Maintenance Inspection Knowledge Compliance Analysis Parties

Document Ref. TMS-IMS01 Page 49 of 50

 EHQMS System Manual
ISO 9001:2015, ISO 14001:2015 & ISO 45001:2018

A.2 Organisation Chart

Document Ref. TMS-IMS01 Page 50 of 50