EHS Audits

Baxter's environmental, health and safety (EHS) audit process verifies that the company’s facilities have EHS programs that achieve regulatory compliance and meet Baxter’s EHS requirements, objectives and goals. The company staffs its audit teams with professionals from the corporate EHS audit group and the EHS organization. ERM Certification and Verification Services conducts certification audits to the International Organization for Standardization (ISO) 14001 Environmental Management System Standard and/or the Occupational Health and Safety Assessment Series (OHSAS) 18001, as appropriate. When auditors identify gaps, the audit team works with facility management to ensure management fully understands the issues.

Throughout the year, the EHS organization reviews the most common audit findings to systematically address identified issues, strengthen corporate policy when needed and prioritize company initiatives. The EHS organization’s functional teams then work to address areas with the most findings. In 2011 and 2010, the area of weakness most frequently identified by EHS audits involved improper handling of materials that may pose risk to employees and the environment.

Baxter requires closure of regulatory nonconformities within 60 days of an audit’s conclusion, and all other nonconformities within 180 days. Baxter’s EHS Audit Escalation Procedure helps inform senior management of any overdue nonconformities.

In addition to facility audits, the corporate EHS group also included several specific regulatory and EHS risk areas in the 2011 audit schedule, such as the following European Union Directives: Registration, Evaluation and Authorisation and Restriction of Chemicals (REACH), Restriction on Hazardous Substances (RoHS), Waste Electrical and Electronic Equipment (WEEE), Packaging, and Dangerous Goods. Baxter will continue to supplement its regular comprehensive audits with targeted regulatory risk audits as warranted.

EHS Audit Program Attributes
Auditors are independent of facilities being audited.
Baxter selects auditors based on technical expertise, EHS auditing experience and language skills.
New Baxter facilities are generally audited within two years of acquisition, although 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's standards are subject to increased audit frequency; for example, a repeat audit in six months.
Audit scope includes regulatory compliance, compliance with Baxter's global EHS requirements 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.
Baxter tracks all audit items until closed, with regions/business units confirming closure.

Baxter selects facilities to audit based on risk profile, management system certification needs and other factors, such as management turnover and negative EHS performance trends.

In 2011, Baxter conducted EHS audits of 25 out of 110 applicable facilities. Of these, nine were in Baxter’s Europe, Middle East and Africa region; seven were in North America; eight were in Asia Pacific; and one was in Latin America.

Corporate EHS Audit Process