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County of Orange, NC RFP #5183 <br />Towards this end, the company is pursuing OSHA Voluntary Protection Program (VPP) status at <br />several operating locations as well as researching the EPA's National Environmental <br />Achievement Track Program for possible implementation at selected facilities in the United <br />States. Our Reidsville, NC facility has one of the first facilities to obtain it VPP status. <br />Regulatory Communications <br />The company proactively reviews, researches, and manages regulatory developments. Specific <br />sources of information include things such as the Bureau of National Affairs, RegScan, and <br />CCOHS. Proactive compliance is also achieved through review of state, provincial, and federal <br />environmental compliance web sites. The process includes information gathering, regulatory <br />analysis, determining the potential impact on the company's business and facilities, <br />communication to the field personnel (e.g., compliance, operations, sales /marketing), providing <br />feedback to the agencies, implementing new programs to meet any new requirements, and <br />providing interpretive guidance on new regulations. Communication mechanisms include: <br />Regulatory Alerts (summary analysis of proposed and final rules); Newsletters ( "Readers <br />Digest" version of regulatory initiatives); and communication from the field on state, provincial, <br />and local issues. <br />Internal Compliance Communications <br />The senior managers of the Environmental Health & Safety Department conduct weekly <br />conference calls with the functional managers and the corporate support staff. In addition to this, <br />each health, safety, and compliance manager submits weekly status reports detailing significant <br />issues. The company also utilizes an Incident Notification Program. With this program, <br />significant incidents are communicated to the Vice President of Compliance via telephone or <br />email within 15 minutes of occurrence. Follow -up reports are submitted within 48 hours. This <br />information is then communicated to the senior management of the company including the <br />General Counsel. <br />On a monthly basis, a Regulatory Compliance Report is issued. This report, which includes data <br />on Health & Safety incidents as well as key performance parameters within the environmental <br />compliance group, is distributed to all senior managers of the company and provides a regular <br />update on the company's performance in these critical areas. We are continuously evaluating <br />new parameters for designation as key performance indicators. <br />Internal Audit Program <br />Striving for continuous improvement, the Corporate Environmental Health & Safety Audit <br />Program also provides facility, functional, and senior management with current information on <br />the compliance status of each Clean Harbors facility. Environmental Health & Safety staff <br />members conduct the audits, and the objective is for each auditor to not audit a facility for which <br />he /she is assigned and directly responsible. The scope of the audits includes evaluation of <br />regulations (e.g., RCRA, TSCA, CAA, CWA, OSHA, among others), Clean Harbors' operating <br />permits, and company policies and procedures. Any deficiencies are captured in a Corrective <br />Action Plan (CAP) and all items are tracked until each is completed. <br />Company Confidential 18 www.cleanharbors.com <br />