Achieving 100% Compliance: Best Practices for Environmental Audits

1. 100% Compliance, 100% of the Time Bill Gill July 18, 2013

2. Background ECAP – Environmental Compliance Assessment Program Third Party Environmental Audit Multi-Media Snapshot Simulates a Regulatory Inspection Attorney-Client Protected Identify and Address Non-Compliances Implement Best Practices

3. Way Before Read Your Permits Keep Permits and Files Organized Check Status of Last ECAP Findings Keep Plans and Procedures Updated Make Sure Training is Up To Date

4. A Little Before Verify Dates for Site Visit are Good for Key Personnel Spot Check Files Respond to Pre-Assessment Questionnaire Make Sure You Have a Space for Auditors to Work If You Didn’t Do ‘Way Before’, Don’t Try to Self-Audit and Correct at the Last Minute If You Did Do ‘Way Before’, Relax

5. During Initial Pre-Briefing with Auditors and Key Personnel (Include Plant Manager and Plant Engineer) Plant Tour Cooperate and Allow Access Some Auditing May Take Place on Off Shifts and/or Include 2 nd and 3 rd Shift Supervisors All Findings will be Included, Even if You Fix Them Daily De-Brief Keep Key Personnel Posted on Status

6. Just After Final De-Brief Call with Key Personnel, Smithfield Foods, Legal, and Auditors Don’t Panic – All Findings and Recommendations are Reviewed Before They Become Final If Anything Needs to be Addressed Immediately – You Will Be Made Aware Remember the Program is Attorney-Client Privileged – Ask Legal about How to Handle Notes and Audit Documents

7. After Final Findings and Recommendations Should be Available in a Few Weeks Set Up an Internal Spreadsheet with What, Who, and When Address ‘A’ Findings First Stay on Schedule Work with Your IOC Coordinator to Keep the Workroom Updated Ask if You Have Questions

8. The Inside Scoop Findings are Typically Similar Across the Company Many Involve Keeping Paperwork Up To Date Read Your Permits to Make Sure Requirements are Being Fully Addressed Plans (SPCC, SWPPP, …) Should Match Actual Site Conditions Names and Contact Info on Documents Should be Correct Keep Files Organized and Accessible

9. More Scoop Signage for Universal & Hazardous Wastes Training as Noted in Your Plans and Procedures RMP Procedures and Training Implemented Reread Your Air Permit Opacity Applies to Everyone Regulated Refrigerants ‘Way Before’ Slide

10. Questions? 100% Compliance, 100% of the Time!