EHS Audits

Baxter's environmental, health and safety (EHS) audit process verifies that the company’s facilities have EHS programs that meet Baxter’s EHS requirements, objectives and goals. The company staffs the 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 they fully understand the issues.

Throughout the year, the EHS organization reviews the most common audit findings to systematically address identified issues, revise corporate policy (when needed) and prioritize company initiatives.

EHS audits identified hazardous materials management as the top finding for 2010, a trend since 2007. The EHS organization’s environmental functional team continues to address this challenge.

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. Baxter’s new EHS information management system, launched in 2010, enables the company’s facilities and corporate EHS audit group to further improve management of these issues.

In addition to facility audits, the corporate EHS group also included the following regulatory areas in the 2011 audit schedule: compliance with regulations and policies that govern dangerous goods shipping; producer responsibility requirements in Europe; Baxter EHS policy related to construction contractors; and focused wastewater audits. The group also continued its collaboration with the company’s Supplier Quality Audit organization to extend its reach to identify significant EHS risks at select suppliers’ manufacturing locations. In 2010, the EHS audit group participated in a pilot of a supplier quality audit and plans to continue this work in 2011. See Managing Supplier Performance for more information.

EHS Audit Program Attributes
Auditors are independent of facilities being audited.
Baxter selects auditors based on technical expertise, EHS auditing experience and language skills.
Facilities that are new to Baxter generally are audited within two years of acquisition, though 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 of all audit items.

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 2010, Baxter conducted EHS audits of 26 out of 110 applicable facilities. Of these, 13 were in Baxter’s Europe, Middle East and Africa region; four were in North America and the Caribbean; five were in Asia Pacific; and four were in Latin America. In 2010, Baxter also conducted audits that focused exclusively on EHS risks related to driver safety, producer responsibility requirements, and supplier EHS issues.

Corporate EHS Audit Process