Compliance Leadership Model

Understand environmental impacts and compliance requirements (ISO 14001 §6.1.3; ISO 19600 §4.5.1, 4.5.2; USSG §8B2.1(a))

Understand compliance obligations

• Top management and facility managers are responsible for knowing compliance obligations.

• ​Process to understand federal and state compliance obligations across all facility locations. Local requirements may be handled store by store.

• ​Process to understand federal, state and local compliance obligations, as well as non-regulatory obligations, across all facility locations and products.

​Process to understand all regulatory and non-regulatory obligations across the value chain, including those that have the potential to impact key stakeholders.

Track changes to compliance obligations

• Changes to compliance obligations tracked on ad hoc basis. Personnel is assigned responsibility for tracking.

• Process to track new and changing obligations across the organization.

• ​Process to track new and changing obligations and to identify opportunities to reduce regulatory obligations where possible.

• ​​Regular tracking of new, changing and proposed regulatory and non-regulatory obligations across the value chain to drive innovation and prepare for the future.

Understand environmental impacts

• ​No formal process to assess environmental impacts.

• ​Assess some environmental impacts and look at how impacts relate to compliance obligations.

• ​Process to identify material environmental impacts and how they relate to compliance obligations is used to prioritize efforts and optimize environmental performance

• ​Organization considers the environmental impacts of its decisions

Understand needs and expectations of key stakeholders (ISO 14001 & 19600 §4.2: USSG §8B2.1(b)(2))

Stakeholder engagement

Facility managers are responsible for understanding the needs and expectations of regulators, with oversight from top management. Engagement is ad hoc or in response to specific issues.

Corporate guidance is provided to facility managers on communication with regulators.

​Engagement with regulators and other key stakeholders (e.g. business partners) allows for analysis and prioritization of significant environmental impacts and stakeholder concerns.

​Regular two-way engagement and collaboration with all key stakeholders (e.g. regulators, shareholders, suppliers, NGOs, etc.) allows for early identification of environmental risks and opportunities and proactive management of stakeholder concerns.

Establish compliance responsibility within the organization (ISO 14001 & 19600 §4.4; USSG §8B2.1(a), (b))

Establish responsibility

Top management responsible for implementing environmental compliance program. Responsibility for facility-level compliance delegated to facility managers, who may determine what is covered by their site-specific programs.

Corporate environmental compliance subject matter experts provide support to facility managers.

An environmental compliance manager oversees the overall program, with responsibility for compliance shared amongst other store and/or functional managers across the organization. ​

Responsibility for compliance resides within top management, which works to ensure compliance is integrated into the overall organizational culture.

Determine scope

​Environmental compliance management is primarily focused at the facility level.

Environmental compliance management covers all business operations within the company.

​Environmental compliance management covers all business activities within the company, including product compliance.

​Environmental compliance management covers the entire value chain, with the intention of preventing business impacts and disruption from non-compliance (note: this may be accomplished through partnerships where legal responsibility may be outside of the company).

Top management leadership and commitment (ISO 14001 & 19600 §5.1; USSG §8B2.1(b))

​Top management support

​The organization’s governing authority is knowledgeable of the compliance program. Specific top management personnel have responsibility for compliance.

Top management commitment to environmental compliance is documented and communicated at all levels.

​Top management commitment and support for environmental compliance is broadly communicated, as well as expectations for the entire organization to live up to that commitment.

​Top management commitment and support for environmental compliance and continuous performance improvement is broadly communicated and driven throughout the organization. Environmental performance is included in performance evaluation and incentives for top management.

Environmental compliance policy

​Standards and procedures to prevent and detect non-compliance. Policy does not necessarily specifically address environmental compliance. The general policy includes a commitment to meet all applicable legal requirements.

Organization may have multiple environmental compliance policy statements across the organization, varying by topic or scope based on how they were developed historically and/or the scope/intent of the policy.

​Organization has an environmental compliance policy that is regularly reviewed and maintained, and includes a commitment to continuous improvement, including environmental performance.

​​Organization has an environmental compliance policy that is regularly reviewed and maintained, and includes a commitment to continuous performance improvement, including environmental performance, throughout the entire value chain (including vendor and contractor policies).

​Planning, objective and target setting (ISO 14001 §6.1.4, 6.2.1, 6.2.2; ISO 19600 §6.1, 6.2; USS USSG §§8B2.1(b)(4); 8B2.1(b)(6);)

Action plans and targets

Includes incentives to perform according to compliance program and disciplinary measures for not taking reasonable steps to prevent or detect non-compliance.

​Annual goals and action plans related to environmental compliance.

​Annual goals and action plans which include continuous improvement of environmental and compliance performance.

​​The organization's overall planning process includes continuous compliance and environmental performance improvement and considers opportunities to drive innovation and competitive advantage. Some goals may be aspirational.

Communication of targets

Reasonable steps to periodically communicate about the compliance program including standards and procedures via training and other communication methods.

Goals and other aspects of the complicance program are communicated internally across the organization.

Goals and other aspects of the compliance program are communicated across the organization and select goals may be publicly reported.

​Goals and other aspects of the compliance program are regularly communicated both internally and externally.

​Store & Facility Operations (ISO 14001 §8.1, 9.1.2; ISO 19600 §8.1; USSG §8B2.1(b)(4))

​Standard Operating Procedures

Some written procedures and training programs explaining how to maintain environmental compliance; ones that exist are generally at the facility level.

​Basic Standard Operating Procedures (SOPs) on environmental compliance.

​More detailed Standard Operating Procedures (SOPs), mostly for environmental compliance but some related to preventing environmental harm. SOPs are regularly maintained and integrated into mainline business SOPs.

​​Standard Operating Procedures (SOPs) cover environmental compliance, as well as prevention of environmental harm and are used to embed sustainability thinking throughout the organization.

​Waste Management

Hazardous waste

Each facility is responsible for hazardous waste management including waste identification, handling, storage, and training, as well as contracting hazardous waste haulers. Limited management oversight of hazardous waste haulers / contractors to ensure compliance with “cradle to grave” obligations of waste generator.

​​Corporate guidance and training for identifying and handling hazardous waste is applied across all facilities as well as guidance on contracts for hazardous waste haulers.

​​Corporate program sets goals to improve hazardous waste compliance performance and reduce the volume of hazardous waste generated. Program uses data and analysis to improve compliance and reduce risk (e.g., reduce the volume of hazardous waste and regulatory obligations, regularly review performance of hazardous waste haulers / contractors). Program includes standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.).

​​​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate compliance and environmental risks (e.g. using cleaning products that are non-hazardous, selecting merchandise that will not become a hazardous waste, regularly reviewing performance of hazardous waste haulers / contractors, etc.).

Other regulated waste

​Each facility is responsible for identifying and following state and local solid waste regulations, as well as contracting waste haulers. Little management oversight of waste haulers / contractors beyond basic due diligence.

​​​Corporate guidance on waste management, including management of specific waste types and management of waste haulers / contractors, is applied across all facilities. Waste diversion and recycling efforts are mostly in response to compliance obligations.

​​​Corporate program sets goals to improve waste reduction and diversion, and uses data and analysis to reduce non-compliance and continuously improve performance (e.g. changing processes to reduce waste generated, regularly reviewing performance of waste haulers / contractors). Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.).

​​​Corporate program sets ambitious goals (e.g. zero waste), encourages innovation, and regularly looks for opportunities to proactively improve performance beyond regulatory requirements (e.g. regularly review waste stream and identify ways to reduce volume of waste generated, and reuse or recycle waste; structure contracts with waste haulers / contractors to encourage waste reduction and diversion and regularly review their performance, etc.).

Hazardous Materials Transportation

​Hazardous materials transportation

​​​Fleet managers, facility managers, shipping personnel, and contractors are responsible for complying with all laws and regulations related to hazardous materials transportation.

​​​Corporate guidance and training related to hazardous materials transportation is provided to fleet managers, shipping personnel, and contractors.

​Corporate program sets goals to improve safe and effective transportation of hazardous materials, and where possible reduce volume of hazardous materials transported. Program uses data and analysis to reduce non-compliance and continuously improve performance (e.g. ensure proper classification and labeling). Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, etc.).

​​​​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate compliance and environmental risks (e.g. minimizing use of hazardous materials).

Storage Tanks

Storage tanks

​Each facility is responsible for knowing and implementing storage tank management requirements.

​​​​Corporate guidance for storage tank management is applied across all facilities.

​​Corporate program sets goals to improve storage tank management, and uses data and analysis to evaluate compliance and identify improvement opportunities (e.g. reducing leaks). Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.).

​​​​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate compliance and environmental risks (e.g. upgrade tanks, conduct regular inspections, etc.)

Water

Water consumption

​​Each facility is responsible for identifying and following state and local water conservation requirements.

​​​​​Corporate guidance for water conservation requirements is applied across all applicable facilities.

​​Corporate program sets goals to reduce water consumption, and uses data and analysis to evaluate compliance and identify improvement opportunities (e.g. water-smart landscaping, rainwater collection systems, low-flush toilets, etc.). Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.).

​Corporate program sets ambitious goals, including environmental performance goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate compliance and environmental risks.

Drinking Water

​Each facility is responsible for identifying and complying with applicable drinking water requirements (e.g. Safe Water Drinking Act or state requirements).

​​Corporate guidance for drinking water requirements is applied across all facilities, where applicable.

​​​​​Corporate program sets goals to improve drinking water management, and uses data and analysis to evaluate compliance and identify improvement opportunities. Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.).

​​Corporate program regularly looks for opportunities to improve performance beyond regulatory requirements (e.g. through high standards for drinking water quality). Where possible, organization works to proactively eliminate compliance and environmental risks.

Wastewater

​Each facility is responsible for identifying and complying with wastewater regulations for drain disposal, including fats, oils and grease (FOG), coordinating with the local Publicly-owned treatment works (POTW) and management of septic systems.

​​Corporate guidance for wastewater requirements, including coordinating with POTWs, is applied across all facilities.

​​​​Corporate program sets goals to reduce wastewater, and uses data and analysis to evaluate compliance and identify improvement opportunities (e.g., ensure proper maintenance of grease traps and reduce drain disposal). Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.) and anticipating when changes to operations may require changes to wastewater systems or permitting.

​​​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate compliance and environmental risks.

Stormwater - post construction

​Each facility is responsible for identifying and complying with ongoing stormwater requirements.

​Corporate guidance for stormwater requirements is applied across all facilities.

​​​​Corporate program sets goals to improve stormwater management and reduce environmental impacts. Uses data and analysis to evaluate compliance and identify improvement opportunities (e.g. design or update facilities to minimize stormwater runoff). Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.).

​​​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements to reduce environmental impacts and, restore damage. Organization works to proactively eliminate compliance and environmental risks (e.g. maintain stormwater structures, design new facilities to eliminate stormwater during operations, etc.).

Stormwater - construction

Construction contractors are primarily relied on for following stormwater regulations during construction, except in states where operators (e.g., retailers) must also obtain permit coverage.

​Corporate guidance is provided to corporate teams supervising construction and construction contractors. Contractors are expected to follow stormwater requirements during construction, and corporate teams supervising construction obtain permit coverage where required.

​​​​​Corporate stormwater management program includes evaluating compliance of corporation and construction contractors as well as efforts to improve environmental performance to prevent damage from stormwater. Building design used to reduce ongoing potential for damage from stormwater.

​Corporate stormwater management program includes evaluating compliance and environmental performance of corporation and construction contractors. Building design is used to reduce or eliminate the potential for environmental damage from stormwater.

Air

Refrigeration and air conditioning emissions

Each facility is responsible for identifying and complying with air emission regulations related to refrigeration and air conditioning systems, including overseeing contractors servicing equipment.

Corporate guidance for air requirements related to refrigeration and air conditioning is applied across all facilities and contractors are required to follow corporate policies.

​​Corporate program sets goals to reduce environmental impacts related to refrigerants, and uses data and analysis to evaluate compliance and identify improvement opportunities (e.g. using refrigerant alternatives that reduce environmental and human health impacts). Program supports compliance and minimized releases through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, active monitoring & repair, etc.).

​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate compliance and environmental risks (e.g. eliminating use of harmful refrigerants).

Other air emissions, odor and noise

Each facility is responsible for identifying and complying with regulations related to odor, noise and other air emissions (i.e. emissions other than those related to refrigeration / air conditioning systems such as emissions from generators, vehicle fleets, etc.).

​Corporate guidance for air, odor and noise requirements are applied across all facilities.

​​Corporate program sets goals to reduce air emissions, odor and noise, and uses data and analysis to evaluate compliance and identify improvement opportunities (e.g. improving energy efficiency of facility and/or vehicles). Program supports compliance through standardized / systematic activities (e.g. training, auditing / inspecting, reporting, etc.) and anticipating when changes to operations may require changes to air emissions permitting.

​​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate compliance and environmental risks (e.g. switching to renewable energy sources).

Emergency Planning

Chemical inventory reporting; toxic release inventory; spill reporting

​Each facility is responsible for identifying and complying with regulations for chemical inventory, toxic release, and spill reporting.

​​Corporate guidance for inventory management and tracking, toxic release reporting, and spill reporting policy.

​Corporate program provides a structure and milestones for chemical inventory management and tracking and toxic release reporting. Spill reporting handled by corporate environmental managers.

​​Corporate program sets ambitious goals, encourages innovation, and regularly looks for opportunities to improve performance beyond regulatory requirements. Where possible, organization works to proactively eliminate chemicals requiring reporting.

Product Compliance & Toxics (ISO 14001 §6.1.2, 9.1.2; ISO 19600 §8.3, 9.1.1) Note: private label manufacturing is not included in this section.

Manage product environmental impacts and requirements

Each facility is responsible for identifying and complying with product-focused requirements (e.g., pesticides, VOCs) at the facility level.

​Process to prioritize and manage product environmental compliance issues within organization's control. Corporate guidance is provided to facilities (e.g. controls to prevent shipping products to specific states or to ensure proper signs and labeling).

​​Process to prioritize and manage product environmental compliance issues, as well as non-regulatory issues (e.g. product certifications) within organization’s control and influence. Corporate guidance is integrated into the buying process, and includes how to conduct due diligence, and reduce regulatory risk and environmental impacts (e.g. standardized procurement guidelines).

​​Process to prioritize and manage product environmental requirements throughout the value chain is integrated into existing business processes. Organization works with suppliers to continuously improve product environmental performance and reduce impacts throughout the value chain (e.g. through product design or selection).

Awareness, competence, and training (ISO 14001 §7.1, 7.3; ISO 19600 §7.2.1, 7.2.2, 7.3.1)

Training and awareness

No formal training programs for environmental compliance, other than those required by law (e.g. training for underground storage tanks, hazardous waste, hazardous materials transportation). As a result, practices may vary across the organization based on local management and experience.

​Relevant staff take corporate training and awareness program as needed. Facility managers provide on-the-job training to ensure people know what to do.

​Corporate training and awareness program is completed by relevant staff as needed. Organization tracks required training as well as effectiveness of the training and uses data and analysis to continuously improve training program.

Basic training, including organizational commitments and policies, is mandatory for all employees to drive culture of compliance. Training on various aspects of environmental compliance is integrated within a broader training management system, and may be extended to contractors or suppliers. Multiple channels are used to enhance training effectivenenss.

Competence

Environmental competence and skills are not required for moving staff or hiring into positions with environmental compliance responsibilities. People with compliance or other business backgrounds may be used instead.

Minimum environmental competence is assessed and assured prior to moving staff or hiring into positions with environmental compliance responsibilities.

​Environmental expertise is a requirement for moving staff or hiring into positions with environmental compliance responsibilities.

​​Environmental expertise is a requirement for moving staff or hiring into positions with environmental compliance responsibilities. Performance evaluation and incentives for these positions include environmental performance.

Internal Communication Mechanisms (ISO 14001 & 19600 §7.4.1, 7.4.2; USSG §8B2.1(b)(4)-(5))

Internal messaging

Limited but reasonable steps to communicate periodically the standards and procedures and other aspects of compliance program through training and information dissemination.

​Regular messaging via one or more communication mechanisms is used to keep staff informed about environmental compliance requirements.

​​Regular, consistent messaging (i.e. coordinated and overseen by corporate) is distributed via multiple channels (e.g., Intranet site, regular meetings, posters, emails, etc.) to keep staff informed and answer questions in a timely fashion. Compliance performance, and some environmental performance, is regularly communicated so staff can optimize activities.

Regular, consistent messaging is aligned with corporate communications policy and corporate business priorities to disseminate information regarding environmental best practices. Compliance and environmental performance is regularly communicated so staff can optimize activities.

Two-way dialogue

System for reporting and seeking guidance regarding potential or actual non-compliance without fear of retaliation. System limited to employees communicating with their supervisors with questions or issues related to environmental compliance.

Designated corporate staff handle internal inquiries related to environmental compliance. System may include mechanisms that allow for anonymity or confidentiality.

​A variety of corporate-wide resources facilitate dialogue and address questions or issues (e.g. designated staff, web resources, discussion boards, hotlines, etc.)

​A variety of corporate-wide resources are used, as well as regular two-way engagement mechanisms, to provide regular updates, receive timely feedback and proactively address concerns.

External Communication (ISO 14001 & 19600 §7.4.1, 7.4.2; USSG §8B2.1(b))

Public reporting

​Limited external communications on environmental compliance, other than reporting required by law.

​Periodic, uncoordinated reporting of environmental compliance activities and performance to external stakeholders (e.g. reports for local communities).

​​​Regular, corporate reports on environmental compliance activities and performance are distributed to external stakeholders.

​Regular, corporate reports distributed to external stakeholders include environmental performance that goes beyond compliance (e.g. implementation of best practices, progress against goals, etc.). Environmental reporting is integrated into existing corporate reporting mechanisms (e.g. annual reports).

Regulatory reporting

​Each facility is responsible for tracking and implementing regulatory reporting requirements.

​Corporate guidance for regulatory reporting is provided to facilities (e.g. notification of appropriate agencies in the event of an incident).

​Corporate systems used to track and implement regulatory reporting requirements (e.g. required notices are listed and scheduled in common calendar system). Incident notifications and root cause analyses are documented in the system to prevent reoccurrences.

​Regular, corporate reviews are conducted to evaluate reporting effectiveness and performance improvement opportunities.

Managing external inquiries

​Inquiries from external parties related to environmental compliance are handled by facility managers without coordination from corporate.

​Corporate guidance related to inquiries from external parties is provided to facilities. Inquiries may be handled at the facility level or routed to a designated responsible person or group.

​​Inquiries from external parties related to environmental compliance are managed in a corporate-wide system. Resources are available to help staff address common questions or issues (e.g. frequently asked questions document).

​Where possible the organization provides position statements and takes a proactive approach to transparency including challenges and underperformance against goals.

Documents and records (ISO 14001 & 19600 §7.5.2, 7.5.3; USSG §8B2.1(b)(4))

Document compliance obligations

​​Compliance obligations are not well documented or made available to all employees, beyond what is required.

​​Compliance obligations are documented and made available to responsible employees.

​​Up to date compliance obligations are documented in a centralized location and classified (e.g. by compliance area, store type, region, etc.) to facilitate easy search and access by all employees.

​​​Up to date regulatory and non-regulatory obligations are documented in a centralized location and classified (e.g. by compliance area, store type, region, etc.) to facilitate easy search and access by all employees.

Document and record control

​No central / formal process for maintaining or distributing environmental compliance related documents and records (e.g. policies, standard operating procedures, etc.), beyond what is required.

​​Designated staff ensure that documents and records are stored in a consistent, easily accessible format. Only authorized personnel have editing rights.

​Formal systems for documentation and recordkeeping ensure information is easily accessible and regularly updated. Systematic process to remove old versions from circulation.

​​Integrated systems for environmental documentation and recordkeeping include information "beyond compliance" (i.e. all environmental policies, procedures, etc.), as well as information on contractors / vendors. Systematic process to regularly update information and remove old versions from circulation.

Emergency response (ISO 14001 §8.2; USSG §8B2.1(b))

Emergency response procedures

​Facility managers are responsible for planning for and responding to environmental emergencies or incidents as required to maintain compliance.

​​​Organization-wide emergency response procedures provided to support planning and response to environmental emergencies or incidents as required to maintain compliance.

​​​Organization-wide emergency response procedures for environmental emergencies or incidents are integrated into the broader emergency management system. The effectiveness of procedures is periodically evaluated, especially after emergencies, and used to continuously improve. Escalation process are built in to help keep management informed of high profile incidents that impact other parts of business.

​​​Organization-wide emergency response procedures for environmental emergencies or incidents go beyond compliance requirements and include avoidance / minimization of environmental harm. Emergency management systems share incidents and best practices across facilities to prevent reoccurrence or avoid incidents altogether.

Emergency response training

​​Training is limited to what is required to be in compliance.

​​Training is provided for staff with responsibility for coordinating / managing emergency responses in a specific area.

​​Training is provided to all managers and involves regular testing of emergency response procedures.

​​​Emergency response training is mandatory for all staff.

Inspections, audits, monitoring and evaluation of performance (ISO 14001 §9.1.1, 9.1.2; ISO 19600 §9.1; USSG §8B2.1(b)(5))

Monitoring and evaluation of performance

Minimal mechanisms to regularly monitor and measure environmental compliance performance.

The organization tracks environmental compliance metrics to evaluate compliance performance on a regular basis.

​Compliance and environmental performance is regularly measured against improvement targets and integrated into management decision making.

In addition to tracking compliance, organization tracks environmental performance metrics that go beyond compliance and address the entire value chain (e.g. supplier performance, product takeback, etc.). Performance is evaluated against improvement targets and integrated into management decision making across the company.

Inspections and audits

Top managers periodically monior and audit operations to detect non-compliance.

​Corporate guidance for regular environmental compliance inspections and/or audits is applied across all facilities.

​Organization-wide system of inspections and/or audits to assess compliance performance. Results are evaluated and compared over time to understand issues, identify solutions, and integrate feedback into management decision making.

​​Organization-wide system of inspections and/or audits to assess compliance performance. Results are evaluated and documented in a central location that ensures easy access by appropriate staff. Predictive measures are used to identify situations that may lead to non-compliance.

Documenting compliance status (ISO 14001 §7.5.3, 9.1.2; ISO 19600 §9.1.7 - 9.1.9; USSG §8B2.1(c))

Documenting compliance status and performance

​Facility managers are responsible for documenting and communicating knowledge of compliance status.

​​Environmental compliance program documents compliance status and results of inspections and/or audits in a central location.

​Formal systems for regularly documenting compliance status, as well as reporting results of compliance and environmental performance to management (e.g. complaints received, corrective and preventative actions taken, audit results, etc.).

​​​Formal systems for regularly documenting environmental performance beyond compliance, as well as reporting results of system performance to management (e.g. complaints received, corrective and preventative actions taken, audit results, etc.). Responsibility is fully delegated throughout the organization as per an integrated recordkeeping policy that covers all recordkeeping requirements.

Audits of compliance management system (ISO 14001 §9.2.1, 9.2.2; ISO 19600 §9.2; USSG §8B2.1(b)(5))

Management system audits

​Top managers periodically evaluate the effectiveness of the management system.

​​​Environmental compliance managers regularly review their programs for improvement opportunities.

​​A formal internal audit of all aspects of the environmental compliance management system is conducted regularly.

​Environmental compliance management system is subject to the corporate audit program and is audited internally and/or externally on a regular basis.

Managing non-compliance, corrective actions and escalation (ISO 14001 & 19600 §10.1, 10.2; USSG §8B2.1(b)(7))

Managing non-compliance situations

​​Each facility is responsible for managing non-compliance, corrective actions and escalation. Top management takes steps to prevent further non-compliance, including making changes to the compliance program.

​​​​Organization has clear, structured processes to respond to and correct non-compliance situations, provide for escalation, and take steps to prevent further non-compliance, including making changes to the compliance program.

​​​Organization regularly reviews and updates its processes to respond to and correct non-compliance situations, corrective actions and escalation. Action plans to address noncompliance events, including responsibility for corrective action, are developed and systematically tracked. Process to determine the root cause of non-compliances.

​Organization’s review includes near-misses. Action plans to address non-compliance are systematically tracked by upper management and include process to determine the root cause of non-compliances, if similar non-compliances exist or could potentially occur, and actions to prevent recurrence or occurrence elsewhere.

Management review and continual improvement planning (ISO 14001 & 19600 9.3, 10.3: USSG §8B2.1(c))

Top management review

​Top management periodically assesses risk of non-compliance and appropriate steps are taken to modify the program to reduce the risk of non-compliance.

​​​Facility managers regularly review performance and risk of non-compliance with corporate environmental compliance managers. Corporate environmental compliance managers regularly discuss program performance with top management and steps to reduce risk.

​Robust process for top management to review the organization's environmental compliance performance, management system and risk of non-compliance. Review includes findings from inspections and/or audits and discussion on how to improve performance and reduce risk.

​​Robust process for top management to review the organization's environmental performance, including performance beyond compliance and risk of non-compliance. Process is integrated within relevant business processes and aligned with overall business strategy and priorities. Review includes adequacy of policies and resources, effectiveness of management system, performance against objectives, and opportunities for continual improvement and risk reduction.