Environmental, Health and Safety Audits
Baxter's environmental, health and safety (EHS) audit process verifies that the company’s facilities have EHS programs that meet Baxter’s EHS requirements, goals and objectives. Baxter staffs the audit teams with professionals from the corporate EHS audit group and Baxter's EHS organization. ERM Certification and Verification Services conducts certification audits to ISO 14001 and/or OHSAS 18001, as appropriate. When an audit identifies gaps, the audit team works with facility management to determine systems that require strengthening.
The corporate EHS audit group reviews EHS audit reports three times a year, communicates trends to the EHS organization and posts the results for review on Baxter’s internal EHS website. EHS personnel also discuss these findings at global and regional EHS meetings, and use this analysis to revise corporate EHS policy and prioritize company initiatives. Two of the top three challenges identified in 2007 – waste management and hazardous materials management – remained in the top three in 2008. However, in 2008 the combined number of nonconformities in these areas decreased by 12 percent, while the number of facility audits increased by 6 percent.
Baxter policy requires closure of regulatory nonconformities within 60 days of an audit’s conclusion, and all other nonconformities within six months. Still, overdue nonconformities have been an issue. In 2008, the corporate EHS audit group continued its focus on reducing the number of overdue nonconformities and increasing the engagement of senior management to more rapidly address those items. This included further refining a procedure to escalate overdue items. The major program focus of 2007, discussing audit issues and probable root causes with facility managers and other key personnel, also increased engagement in the audit process.
As discussed in Baxter’s 2007 Sustainability Report, the audit group in 2008 evaluated other risk areas not typically managed at the facility level. Reviews of global chemical regulations and fleet safety identified areas that required additional focus.
In 2008, Baxter engaged two experts in the field of EHS auditing to review the company’s EHS audit program and provide recommendations for improvement. The review did not reveal significant gaps in the audit program. Baxter has evaluated the recommendations for future action. For example, Baxter has begun taking action on a recommendation associated with ensuring consistency among auditors globally.
Baxter selects facilities to audit based on risk profile, certification needs and other factors, such as management turnover and negative performance trends. In 2008, the EHS audit team expanded its audit performance rating system from four to five tiers, allowing more differentiation among audited sites.
In 2008, Baxter conducted EHS audits of 35 out of 110 applicable facilities. Of these, 14 were in Europe, 12 were in North America and the Caribbean, seven were in Asia Pacific and two were in Latin America.
| EHS AUDIT PROGRAM ATTRIBUTES |
| Auditors are independent of facilities being audited. |
| Baxter selects auditors based on technical expertise, EHS auditing experience and language skills. |
| Each year the company audits about 30 percent of the total number of manufacturing and research and development facilities, and large warehouses and offices. |
| Facilities that are new to Baxter generally are audited within two years of acquisition, though regional and business unit personnel are required to conduct a thorough review of these operations within the first year. Short-notice audits (seven-day notification) are conducted, as appropriate. |
| Facilities found to operate below Baxter standards are subject to increased audit frequency; for example, a repeat audit in six months to two years. |
| Audit scope includes regulatory compliance, compliance with Baxter’s global EHS requirements, accuracy of a sampling of EHS data submitted to corporate EHS for reports, and the effectiveness of EHS management systems. |
| The audit group prepares comprehensive audit checklists specific to the facility operations and applicable regulations. |
| Regions/business units conduct EHS reviews of facilities in years between corporate EHS audits, and facilities assess their own programs annually. |
| The company must close regulatory nonconformities within 60 days of the audit’s conclusion, and all other nonconformities within six months. |
| Baxter tracks all audit items until closed. |
