Environmental, Health and Safety Audits
Baxter's environmental, health and safety (EHS) audit process helps the company manage EHS risk and ensures that EHS programs are in place and effective, even as the company's operations and product base expand. Baxter's EHS audit program is staffed by members of the EHS audit group, other Baxter EHS professionals and external EHS auditors from ERM Certification and Verification Services.
Auditors from outside a given facility examine facility, business unit, country and corporate programs. Audit frequency depends on the level of EHS risk at a facility, the status of program development, time elapsed since the previous audit, EHS staff turnover and other risk factors. Baxter EHS professionals audit approximately 25 percent or more of the company's facilities per year, and also may conduct short-notification audits. Baxter additionally requires each facility to perform annual self-assessments.
Typically, facilities that seek ISO 14001 and/or OHSAS 18001 management system certifications are audited every three years. Low-risk facilities, such as offices and small warehouses, are audited every four to five years and in some instances, every eight years. Audits of certain smaller facilities where multiple locations are managed as a collective unit, such as plasma donor centers or product distribution centers, are based on visiting a representative sample of like facilities.
For newly acquired facilities, Baxter requires EHS personnel to conduct a thorough review of operations within the first year followed by a corporate EHS audit within two years.
During an EHS audit, auditors check compliance with regulatory and global company requirements, evaluate the facility's EHS management systems and review the accuracy of data submitted for EHS reports. In addition, audits evaluate the facility's performance in key areas, such as risk reduction, accident prevention and environmental-impact reduction.
The corporate EHS audit group reviews EHS audit results three times a year to identify systemic strengths or weaknesses in EHS programs. Common issues are posted on Baxter’s internal EHS web site for discussion at company and regional EHS meetings. Facilities must determine if these issues exist at their sites, and address them if so. In addition, EHS uses these issues to advise company EHS policy and to prioritize corporate initiatives.
For example, in 2006 audits identified the hazard identification and risk assessment process as a common EHS weakness. To address this, EHS reengineered this process and introduced a new risk assessment process at Baxter’s 2007 Global EHS Conference in July.
In 2006, the corporate EHS audit team audited approximately 25 percent of Baxter's major operations – 25 independent audits that covered 23 facilities and two assessments of the company's global ISO 14001 certificate, one of the two included an assessment against OHSAS 18001 certification. Of the 23 facilities audited, nine are in North America, 10 are in Europe, two are in Asia Pacific and two are in South America.
Baxter seeks to ensure that all operations globally meet or are moving toward the performance level required by the company's EHS policies. For 23 facility EHS audits conducted in 2006, the EHS audit group applied a four-tiered performance rating system to report overall performance to facility, business unit and corporate management, with the following results:
- Exceptional (exceeds company performance expectations): one facility;
- Good (meets expectations): 17 facilities;
- Poor (does not meet expectations): five facilities; and
- Very poor (requires immediate attention): zero facilities.
If a facility is found to operate below Baxter standards, it is subject to increased audit frequency; for example, a repeat audit in six months to two years. Conversely, audit frequency decreases for facilities with excellent EHS performance.
To ensure timely closure of identified issues, the audit program tracks nonconformities identified through audits and governmental inspections using Baxter's web-based EHS information management system. Proper closure of identified items is ensured at subsequent site visits.
To ensure that corporate EHS audits provide value to facilities, the audit group provides facility EHS managers and plant managers with a questionnaire after each audit; results are used to improve the program where appropriate. For example, in 2006 the team improved communication with plant managers and their management teams about the issues identified and their causes.
