the processof self audit from start to finish
TRANSCRIPT
The Process of Self Audit From Start to Finish
Tom MillerVP & GM Environmental Affairs
Nucor Corporation
Who is Nucor?
• Largest Steel Producer in the U.S.• Capable of producing almost 27 million tons per year
• North America’s Largest Recycler• Recycled 21,100,000 tons of scrap metal in 2017
• Over $20.2 Billion in Sales in 2017• #151 in Fortune 500
• More than 27,000 ‘Teammates’ at over 220 facilities in North America
Where is Nucor?
Overview
• 244 Facilities • Steel Mills
• On‐site environmental team
• Products Facilities• 1 coordinator overseeing Environmental & Safety
• 7 Corporate Environmental Teammates
Overview
• Audit program handled in house– 1 Audit Coordinator– Each audit is led and performed by environmental teammates throughout corporation
• Legal counsel present – Provides confidentiality
Role of Legal Counsel
• Attorney/client privileged information• Present for entire audit • Provides follow‐up documents with findings, recommendations, and action plan
• Available for questions and assist at any point in process
Scheduling
Mills vs Products Facilities• 3 years for bigger/higher risk facilities• 5 years for small/lower risk facilities
– After initial audit IF audit findings were low risk – Little to no turnover in on‐site environmental teammate(s)
Team
Led by Teammates• Lead & Co‐Lead (Managers)• 1 Legal Representative
• 3‐5 Engineers/Coordinators• 1 Corporate Representative
Timeline: Pre-Audit
• 6 weeks: Facility posts all permits and plans on Nucor intranet
• 3 weeks: Audit Team Conference Call• Review previous audit report • Make assignments• Identify research needs• Discuss logistics
Pre-Audit
• Audit Coordinator: notifies Facility and Team of deadlines, requirements, scheduling, and missing documents.
• Compare permits/paper to actual • Review remaining permits/plans
Bulk of permit and plan review should be completed PRIOR to arriving on‐site
On-Site Audit: Opening Meeting
Opening Meeting:• Meeting with facility management and supervisors
– Led by designated lead environmental manager
• Review purpose of audit – Highlight “here to help” role
• Importance of confidentiality
On-Site Audit: Audit Process
• Initially, focus on compliance paperwork• Walk through of facility
– Exterior first– Cover entire facility – Pictures taken throughout
• Compliance paperwork reviewed throughout• Staff for multiple groups
On-Site Audit: Findings
• All findings documented• Draft audit findings entered into protected site
– Access for corporate, counsel, auditors and facility only• Findings include:
– Preliminary finding classification– Affected program– Location at facility– Finding; observation and comments for possible resolution– Citation to applicable law, regulation, permit or plan
On-Site Audit: Findings
On-Site Audit: Classifications
• Corrective Actions
• Preventative Actions
• Deficiencies
• Deviations
On-Site Audit: Summary Prep
• Audit team works with facility environmental staff – Classifications of findings– Presentation for closing meeting– PowerPoint of major findings prepared and agreed on
On-Site Audit: Closing Meeting
• Present findings
• Audience: facility managers, supervisors and appropriate leads
• Address questions/concerns
Post Audit
• Environmental Audit Report – 30 days after conclusion of audit • Prepared by counsel
• Environmental Audit Close Out Plan – 30 days after Audit Report • Prepared by facility
• Close Out Plan Evaluation – 30 days after Close Out Plan • Prepared by counsel
• Draft Audit Completion Report – 180 days after Plan Evaluation • Prepared by facility
• Final Audit Completion Report – 60 days after Draft Completion Report
• Prepared by counsel after meeting with facility
Post Audit
• Correction timeline– Corrective Actions ‐ Resolved within 60 days– Preventive Actions ‐ Resolved within 120 days– Deficiencies and Deviations – Resolved within 180 days
Audit Tracker
• Counsel and Audit Coordinator maintain for compiling results
• Looking for:– Trends showing general problem areas– Turnaround times– Audit rotation
Successes and Challenges
Successes• Open dialogue with facility
– “Tell us what’s wrong”
• Quick status update on facility as teammates transition• Teammates learning from teammates
Successes and Challenges
Challenges• Having all permits/plans reviewed prior to audit• Fully closing out plan
– Findings tied to capital improvements– Out of site, out of mind
Questions?
Tom MillerVP & GM Environmental Affairs
Nucor Corporation [email protected]
704‐366‐7000
Rolly SaulsAudit CoordinatorNucor Corporation
[email protected]‐353‐9056