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GLOBAL PROGRAM ELEMENTS

EMS Network's Basic Program Elements are readily adaptable for use in international contexts.

Foundation

  • Technical background of operations
  • Assessment of aspects and impacts
  • Participation of internal and external experts in technical, scientific, regulatory and managerial aspects of operations

Policy

Drafted to articulate the Company's approach to environmental practices and international operations and to address the broad concerns the company faces.

Technical guidance on implementation

  • In conjunction with internal and external experts, development of guidance on specific key activities that have the potential to impact human health and the environment
    • "Core" volume with guidance which is applicable to all operations
    • Individual volumes with guidance which is specific to certain
      operations or levels of management
  • Summaries of applicable regulations

Training

  • Training for management
    • Policy, technical sessions (including risk assessment/risk management), goals and milestones
  • Training for operations-level personnel (some in conjunction with vendors)
  • Training of appropriate personnel in regulatory requirements
  • Training/information for certain suppliers / subcontractors
Self-assessment and validation processes
  • Self-assessment process. Database of assessment responses with "follow up" areas flagged. "Good news" entries also provide resource for external communications. Milestones and progress recorded
  • Validation: Peer review & spot-checks
    • Internal technical review by people familiar with operations and issues
    • Selected site follow-up internal and external technical/regulatory
      team
    • Systemic peer review / validation process. Peer review team includes knowledgeable internal personnel from similar operations
  • Internal Auditing at local level
  • Periodic technical and regulatory review of outstanding issues, recommended resolution and status
    • Includes information from division engineers and environmental coordinators
Reporting to management and corrective actions
  • Management review. Periodic review by management of EMS and significant issues
  • Corrective action
    • Development sessions, where significant issues are address and resolutions a proposed
    • Activities not meeting Company standards are corrected internally, or where appropriate, with involvement of external experts
  • Technical support database
    • Confidential and privileged technical reports and recommendations available to those who need to know, including confidential e-mail capability
  • Periodic reports to management
    • Quarterly update reports on status of identified issues and environmental management in international operations
    • Annual/biannual report providing more comprehensive picture of status issues, accomplishments and state of environmental management
Outreach
  • Work with environmental and social Non-government organizations to identify concerns and provide responses concerning the Company's environmental and social performance
  • Response library of
    • Prepared responses to standard consumer requests
    • Responses to more sensitive questions commonly asked
    • Responses to specific criticisms or concerns
    • Information developed to address public interests groups on environmental, social and labor issues