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ECAP Before, During & After

ECAP Before, During & After. 100% Compliance, 100% of the Time Bill Gill July 18, 2013. Background. ECAP – Environmental Compliance Assessment Program Third Party Environmental Audit Multi-Media Snapshot Simulates a Regulatory Inspection Attorney-Client Protected

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ECAP Before, During & After

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  1. ECAPBefore, During & After 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 2nd and 3rd 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!

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