2. The Evolution of EHS Auditing from Regulatory Compliance to Continuous Improvement David E. Downs, CIH, CSP President EHS Management Partners, Inc.

3. Copyright, EHS Management Partners, 1999

6. Top Five Signs That it is Time to Schedule an EHS Audit ÎYou’ve been in town so long your spouse has started to recognize you on sight. ÍIt’s been over two months since you have worked a 60 hour week. ÌOne of the plant manager’s has actually returned one of your follow-up calls. ËYour boss says, “We’ve got all the plants in compliance, so you should be able to take on some new responsibilities, right?”

7. Copyright, EHS Management Partners, 1999 And… the Number One Sign That it is Time for an Audit... Ê The EHS staff at the plants are showing signs of working on their own priorities.

8. Copyright, EHS Management Partners, 1999 Introduction 4 Where we have been: –Legal Liability Concerns –Compliance Driven –“Binary” design –Attorney directed –Punitive Follow-up

9. Copyright, EHS Management Partners, 1999 Diminishing Returns - Why? 4 Finite Goal - Compliance 4 Redirection of Priorities 4 The “Learned” Response

10. Copyright, EHS Management Partners, 1999 Design to Drive - Continuous Improvement 4 Compliance is not the End-Point 4 Other Issues than Compliance 4 Assessment of Significance

11. Copyright, EHS Management Partners, 1999 Design to Drive - Continuous Improvement 4 Improvement is Incremental 4 Goals less than Full Compliance 4 Evaluation of Local Issues

12. Copyright, EHS Management Partners, 1999 Design to Drive - Continuous Improvement 4 Root Cause Assessment 4 Assessor/Partner 4 Participation and Communication

13. Copyright, EHS Management Partners, 1999 Legal Issues 4 The Traditional Approach... –Directed by Legal –Communication Restricted –No Assessment of Significance –Only Corrective Action- Full Compliance 4 …Will Not Work in Continuous Improvement Model

14. Copyright, EHS Management Partners, 1999 Legal Issues 4 Assessment Vs. Audit –Audit - Carries legal implications - –Assessment - Routine Management Function 4 Product of Assessment - Action Plan, not Findings

15. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Open-ended Questions: –How effective is…? –How well developed is…? –To what extent has the facility …? 4 Impossible to answer “Yes” or “No”

16. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Implementation Levels –Five Levels –Specific to each Question –Describe typical evidence found by the Assessor

17. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Generic Implementation Level Definitions Level One - No attention to the area. No evidence of activity or recognition of the EHS management area addressed by the question.

18. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Generic Implementation Level Definitions Level Two - Serious lack of attention to the area. Some evidence of recognition, but implementation has been minimal; May have “just started”. Most of the requirements have not been addressed and/or there is little documentation of activity.

19. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Generic Implementation Level Definitions Level Three - Area has addressed, but not in a consistent, complete or continuous manner. Most of the requirements have been completed and documented, but some specific areas still need to be addressed, communicated, or documented.

20. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Generic Implementation Level Definitions Level Four - Area has been addressed in a well- developed and effective manner. Procedures/policies for implementation are documented and communicated within the organization. There is evidence of a good understanding of the requirement throughout the organization.

21. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Generic Implementation Level Definitions Level Five - Area has been addressed in an outstanding manner, representing a sustained “best-of- class” approach that is fully documented; or, particularly effective and innovative approaches.

22. Copyright, EHS Management Partners, 1999 EHS Assessment Tool Design 4 Management Categories –Used to Establish Assessment Scope –Used to Summarize Results 4 Guidance Section –Helps Assessor evaluate Questions, Select Implementation Level

23. Copyright, EHS Management Partners, 1999 Assessment Process 4 Typical Assessment Steps –Conduct interviews, review documents, site inspections –Enter data into database –Review results –Determine priorities, set new goals –Develop Action Plan

24. Copyright, EHS Management Partners, 1999 EHS Assessment Application

25. Copyright, EHS Management Partners, 1999 EHS Assessment Application

26. Copyright, EHS Management Partners, 1999 EHS Assessment Application

27. Copyright, EHS Management Partners, 1999 EHS Assessment Application

28. Copyright, EHS Management Partners, 1999 EHS Assessment Application

29. Copyright, EHS Management Partners, 1999 EHS Assessment Application

30. Copyright, EHS Management Partners, 1999 Driving Continuous Improvement 4 Initial Assessment 4 Goal Setting 4 Action Plan Development 4 Implementation 4 Re-Assessment

31. Conclusion 4 Improved Efficiency 4 Attention to Value