270 likes | 359 Views
Presentation Overview . Our Programs Our Performance Regulatory Climate. Smithfield Operations. Where Our Program Began. Our Program. Environmental Policy Communicates our aim to lead the industry and continually improve Guidelines Corporate and Senior Management
E N D
Presentation Overview Our Programs Our Performance Regulatory Climate
Our Program • Environmental Policy • Communicates our aim to lead the industry and continually improve • Guidelines • Corporate and Senior Management • Corporate level officer • Corporate level Environmental Affairs and Legal • Senior-level Environmental Coordinators at each IOC • Facility Environmental Coordinators at each location • Systems • EMS/ISO 14001 • EMS auditing • Environmental Compliance Assessment Program (ECAP) • Incident Notification System • Training • Corporate level Environmental Compliance Committee (ECC) reporting/quarterly mtgs • Annual Conference and Awards
Sustainability ISO 14001 Certification and EMS Systems Environmental Awards Program Web-based Training Program Environmental Compliance Committee (ECC) PQA Plus® Certification Conversion to Group Housing Animal Welfare Committee Limited use of Antibiotics CO2 Stunning State-of-the-Art Facilities/ Technology Food Safety Policy Food Safety Auditing Traceability Cloning Policy Sodium Policy Employee Injury Prevention Management System (EIPMS) Corporate Management Safety Awards Human Rights Policy Learners to Leaders® Helping Hungry Homes® World Water Monitoring Day FFA Environmental and Natural Resources Award
Enforcement - Trends and Challenges • Obama EPA’s Voluntary Programs and Collaboration Diminished • More Enforcement Referrals to DOJ • CAA and CWA permit noncompliance, Worker Endangerment Initiative with OSHA, CAFOs, Stormwater • Federal enforcement for items not previously considered • More severe penalties than in the past • Looking for opportunities to prosecute individuals - not just officers and managers • Gov’t wants to send a strong message and make headlines – particularly in election season
Regulatory Basis • CWA, CAA, RCRA, state equivalents are strict liability for civil purposes • $37,500/day/violation • “Knowing violations” authorize felony liability • Gov’t must show you were aware of nature of your acts; not that acts violated the statute
Civil/Criminal • CWA: criminalizes negligent conduct involving discharges to waters of the U.S. • Sec. 309(c)(1) • Includes NPDES permit requirements, etc. • CAA: criminalizes negligent conduct involving releases of hazardous pollutants or extremely haz. subtances • Sec. 113(c)(4) • But also requires imminent danger of death or serious injury • Line between civil and criminal is hazy
Hazy Line • “Enforcement discretion” • Lots of cases – fall into 4 categories: • Failed to fix a known problem • Failed to take reasonable precautions – e.g., failure to maintain • Injuries and/or environmental impacts • Target perceived as a “bad actor”
McDonald’s Supplier Sustainability Award (2010) • Supplier best exemplifying McDonald's vision and principles for sustainable supply • McDonald’s Best of Green (2011)
Challenges The plight of farm animals extends far beyond antibiotics–MI State News, November 2, 2010 'Good' food movement expands as outbreaks, recalls prove dangers of industrial agriculture –Natural News, October 17, 2010 Conglomerated food industry harms eaters, farmers–The Daily Campus at UConn, November 1, 2010 Factory animal farms spew toxic chemical fumes, poisoning neighbors–Natural News, November 1, 2010 Industrial farming puts ecosystems at risk of collapse, warns Prince Charles–The Guardian October 25, 2010 Obesity in America: Are Factory Farms, Big Pharma and Big Food to Blame?-HuffingtonPost Oct. 25, 2010 Activist, author targets food industry in new book–The New Mexican October 26, 2010
Take Aways • What you do at your location is IMPORTANT • An issue your location/operating company is a SMITHFIELD FOODS issue • When in doubt, be consistent with our commitment to continuous improvement and leadership