Getting the most out of Document Review

1. Getting the most out of Document Review David Chatfield David Chatfield Associates 1

2. Overall Process • Communicate to and involve Team Members in the process • Identify and select an auditor • Set up Document Review arrangements • Prepare the checklist • Compile the supporting documentation and send to auditor 2

3. Overall Process - continued • Respond to auditor’s phone questions • Review the report and clarify any misunderstandings • Communicate the report to the team • Develop an action plan to address the non conformances • Complete the action plan • Prepare for the on site audit 3

4. Communicate to and involve Team Members in the process • Implementing and maintaining a management system is a team effort • Present to the Management Team the overall EHS&S management system and confirm their roles • Brief all employees on the status of the management system development • Emphasize the value that this type of EHS&S management system brings to a facility • Get people involved 4

5. Identify and select an auditor • SOCMA has a list of approved auditors • The selected auditor needs to be independent and objective. • The selected auditor will not have been involved in the design of your EHS&S management system • Consider the independence aspect (financial stake, family member, ex employee) • Review the auditor’s procedure for carrying out the audit • Confirm availability • Cost & terms (including close out arrangements) • Usual company procedures for approving vendors • Need for confidentiality agreement • Need for background check • Agree scope (tier, facility, excluded operations) 5

6. Set up Document Review arrangements • Agree when the package is going to be received by the auditor • Agree format of the package (electronic, hard copy, mixture) • Agree when auditor will complete the review • Leave time for clarifying misunderstandings • Leave time for agreeing an action plan 6

7. Prepare the checklist • Use the input for the PEV as a starting point for the description of practices • Update with the improvements you have made since the PEV • Cover E, H, S, & S 7

8. Compile the supporting documentation & send to Auditor • Identify the key documents that describe the management system procedures • Provide examples that the procedure has been implemented • Consider if there is anything that should be confidential and how that will be handled particularly security procedures • Master lists of operational controls can demonstrate the breadth of your system • Master list of all EHS&S documents is very useful • Table of contents of certain procedures such as the Emergency Plans is very useful 8

9. Respond to auditor’s phone questions • Phone call clarification is very likely • Try not to be defensive • However support your system if it works for you 9

10. Review the report and clarify any misunderstandings • Make sure you understand the auditors opinion • Contact the auditor if you believe the auditor has not understood your management system • If you disagree with the auditor there is a resolution process 10

11. Communicate the report to the team • The auditor will identify some of your best practices. This is an opportunity to reinforce those good practices • Communicate the non conformances and the underlying issues 11

12. Develop an action plan to address the non conformances • Get team involvement • Get the Facility Manger to sign off on the action plan • Get the Auditor to agree that the action plan is acceptable • Prioritize on the most important • You have 6 months (at least) to close out • Include time for auditor close out 12

13. Complete the action plan • Completion of the action plan includes close out by the auditor 13

14. Prepare for the on site audit • Keep the team involved • Build your management system (continual Improvement) 14

15. Contact Details David Chatfield David Chatfield Associates LLC 13 Quail Run Newburyport, MA 01950 P: 978 764 9040 F; 978 935 9004 E: dchatfield@davidchatfield.com W: www.davidchatfield.com 15