Individual Unit Function: Ecology Procedure No.: EC-13 Page: 1 of 5. Preparer: Owner: Approver: SIH Team Leader EHS Team Leader EHS Hub Director

Transcription

1 BASF Corporation Title: EHS Compliance Assessment Process Procedure No.: EC-13 Page: 1 of 5 Chemicals Reviewed: 09/08/17 Effective: 09/13/17 Supersedes: 001/01/14 RECORD OF REVISIONS Date Details of Change 07/07/05 - Added Record of Revisions table. - Clarified notes that must be made to the Comments and Follow-up fields for action items and minor deficiencies. - Eliminated the requirement for Y to be deleted from the Follow-Up column when deficiencies are corrected. 01/17/06 - Deleted references to Handheld PC - Added references to the CAP database (4.1.1 and appendices) - Revised from 4 to up to 6 hours for each monthly audit - Revised how findings of noncompliance are tracked. - Added the Reporting section - Added Appendix B 08/23/06 - Added revised link 05/08 - Updated Sections 4.1, Deleted Section 4.5.4, 4.5.5, 4.6, and /13 Significant changes to all sections. 09/17 Updated titles and link to CAP database

2 BASF Corporation Title: EHS Compliance Assessment Process Procedure No.: EC-13 Page: 2 of 5 1. PURPOSE The purpose of this procedure is to establish a process by which Environmental, Industrial Hygiene, and Safety (EHS) requirements should be periodically audited by the EHS Hub through the spot-checking of records, field conditions, and/or job activities. The intent shall be to monitor EHS requirements at least once per audit cycle. 2. DEFINITIONS 3. SCOPE This procedure applies to all EHS requirements defined by applicable federal, state and/or local governmental agencies, all BASF policies/procedures, and all Geismar site policies/procedures. The audit scope excludes include one-time applicability determinations, one time reports/notifications, design criteria, and obvious daily tasks/frequent tasks. 4. PROCEDURE 4.1. Each Geismar EHS representative will be responsible for completing their assigned protocols according to the schedule identified in the CAP database. 4.2 Audit results shall be saved to the Access database by the end of the month for which the respective protocol is scheduled. The database is located at B:\GLOBAL\2063-BASUS\GEISMAR\EHS\ Hub\General Shared\Compliance Assurance Database The list of EHS protocols is available in the database 4.3 Verification of identified items should include ensuring that the task was performed, that the documentation is in order, and/or that the field condition is acceptable A representative sample, for each specific requirement, may be selected for auditing according to the following table: Estimated Size of Population Minimum Sample Size

3 Procedure No.: EC-13 Page: 3 of >250 5% of total If problems are noted then additional samples may be selected to determine if systemic problems are occurring. 4.4 Performance shall be measured via the following scoring system: Score Blank 0 Explanation Not Applicable 0-10% of the samples are in compliance OR Not in Compliance for general items not requiring samples % of the samples are in compliance % of the samples are in compliance % of the samples are in compliance % of the samples are in compliance % of the samples are in compliance OR In Compliance for general items not requiring samples Some protocol items may not require the auditor to review samples (ex. Does a written program exist regarding employee participation? ). In cases like this, the score shall only be documented as a 0 or a Findings of Non-Compliance Findings of non-compliance should be documented and communicated to the responsible manager(s) If a deficiency cannot be immediately addressed, then appropriate action must be taken to ensure the deficiency is resolved. This may involve, but is not limited to, assigning action Items to the responsible individual(s), using the Action Tracker (ACT) system. 4.6 Reporting An Executive Summary should be created for each audit that is conducted for a given unit/cluster/department,. Executive Summaries should be documented in the CAP database upon entry of the audit data results.

4 Procedure No.: EC-13 Page: 4 of The Executive Summary will be communicated to the responsible Production Managers(s) or service group manager(s) by each respective EHS representative Summaries of systemic findings may be communicated during the EHS Leadership meeting and/or Tactical MLT as appropriate. 5 Changes to Audit Protocols 5.2 Any suggested changes to an audit protocol must be reviewed/approved by the respective subject matter expert, as identified below: SIH Protocols S/IH Team Leader Unit and General Environmental Protocols Environmental Team Leader Emergency Response ER Specialist PSM/RMP PSM/RMP Specialist Waste/Water/EPCRA Water/Waste Specialist 5.3 The protocol owner shall modify the Access database on the shared drive to reflect any approved changes. 5.4 Once protocols are updated, the process owner should notify all auditors affected by the change. 5. RESPONSIBILITIES 5.1 Each EHS Specialist is responsible for: Completing their assigned protocols Tracking areas of non-compliance until resolution Saving audit results to the database Creating Executive Summaries for each audit. 5.2 Subject Matter Experts are responsible for: Completing protocols as assigned Periodically evaluating the audit results to determine if systems or programs issues need to be addressed Approving suggested changes to protocols and modifying the respective protocol spreadsheets.

5 Procedure No.: EC-13 Page: 5 of The EHS Hub Director is responsible for the overall implementation of this procedure. 6. EXCEPTIONS 6.1 The EHS Hub Director and/or the EHS Team Leaders may approve use of an alternate EHS compliance assessment tool. This applies to any and all sections of EC-13.