Page 9 - SAMA HSE PLAN

Sama Global HSE Plan December 2023

releases, or test results. Such self‐reporting sometimes informs the EPA of a violation or of an activity
which the agency may investigate. Failure to report or notify can result in serious consequences as well.

3. Employees or Other Parties – If an agency hears about a violation from an employee or another person,
it will not usually issue a citation based solely on such information. It may write to request information
regarding a particular incident or activity, or it may perform an inspection.

Depending on the seriousness of the violation (degree of harm to the environment and to human health,
intent of the operator), violations can be subject to major fines and/or imprisonment. When the agency
inspects a client’s site, it could also inspect Sama Global operations. If fines are assessed against the
Client, Sama Global may also be liable to pay fines based on its contractual obligations to the client.
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5.3 HSE Department Support

Sama Global's HSE department is responsible for carrying out Sama Global's environmental compliance policy
and Programs Company wide. The HSE department role is to provide technical support to the project sites.
HSE department must always be informed about significant environmental compliance activities at project
sites, and certain environmental records will be filed both with HSE department and at the project location.

HSE department responsibilities include:
 Providing technical support to projects.
 Assisting projects sites with the preparation of permit applications, notification forms, and other
environmental documents for regulatory agencies.
 Maintaining environmental records in the HSE Dept central filing system.

 Assisting project sites in developing an employee environmental training program.

 Auditing project sites and providing procedures to establish and maintain environmental
compliance.

 Acting as liaison with environmental agencies in obtaining or negotiating permits and responding to
notices of violation.

 Updating Manuals.

 Reviewing all correspondence and submittals to regulatory agencies.

6. USER FEEDBACK

To provide users of this manual with a method of recommending improvements to the manual that would
enhance safety, streamline work processes, and reduce costs without sacrificing quality or
management/supervisory control, Sama Global has developed the User Feedback Form, as shown in
Appendix 1. This form helps senior staff propose changes that eliminate non‐conformances arising during
quality audits. It also establishes a system for review and assessment of improvements.

The User initiates the User’s Feedback Form in Appendix 1, with the original submitted to the HSE
Department. The HSE Department records receipt and comments. The HSE department then reviews the
suggestion, comments as appropriate, and determines if the improvement should be implemented.
Reasons not to implement shall be given. HSE returns a copy of the completed form to the originator (user).

If response to the feedback form is expected to take longer than one week, HSE shall advise the originator of
receipt by electronic mail or memorandum and give an expected response date.

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