External EHS Reporting and Community Relations Plan Template

External EHS Reporting and Community Relations Plan

Table of Contents

I.OBJECTIVE AND SCOPE
II.DEFINITIONS
III.ASSIGNMENT OF RESPONSIBILITY

A.Reporting and External Relations Manager

B.Management

C.Office of Regulatory Affairs [for facilities in North America]

IV.PROCEDURE
V.TRAINING

A.Employee Training

B.Training Records

VI.REFERENCES

NCH Policy References

VII.APPENDICES
VIII.DOCUMENT CONTROL

External Reporting and Community Relations Plan

for

[Company Name/Location]

I.OBJECTIVE AND SCOPE

The objective of the [Company Name/Location] External EHS Reporting and Community Relations Plan is to:

  1. Comply with governmental environmental, health and safety (EHS) requirements for reporting.
  2. Respond to EHS inquiries from external sources.
  3. Enhance and maintain sound relationships with the communities in which NCH operates.

External EHS inquiries and/or requests shall be addressed at a senior organizational level.The procedures described in this Plan are intended to facilitate compliance with applicable governmental regulations. If there is a conflict between this Plan and a governmental regulation, the governmental regulation will apply and this Plan will be modified. However, all other requirements in this Plan apply even if more stringent than governmental regulations.

II.DEFINITIONS

External EHS reporting. Any report, notification data or other information that is required to be submitted to any governmental or jurisdictional agency concerning environmental, health or safety requirements applicable to [Company Name/Location]. Such would include, pesticide sales reports, air emissions reports, data submissions required under a permit, waste generation or disposal reports, waste water discharge information, inventory lists, chemical usage reports, injury and illness reports, etc.

External party or Community.Any person, business, entity, newspaper, television station, radio, association, etc that is not part of NCH Corporation.

III.ASSIGNMENT OF RESPONSIBILITY

A.Reporting and External Relations Manager

[Responsible Person] as the Reporting and External Relations Manager (RERM) shall manage this Plan for [Company Name/Location]. The RERM shall also maintain all reports submitted to governmental agencies and all supporting documentation in accordance with legal requirements and the [Company Name/Location] Record Retention Plan. The RERM is responsible for gathering all required information and either preparing and submitting the reports or providing such information to the appropriate person within the company designated to prepare and submit the report.

The RERM shall also coordinate with the Facility Manager regarding the status of all reporting and location of all reporting records.

B.Management

[Responsible Person] is the Facility Manager for [Company Name]. Facility Manager will provide adequate support to RERM to ensure all reports are properly prepared and timely submitted. Facility Manager will ensure proper adherence to this plan through annual review of all reporting requirements and this Plan.

The Facility Manager shall be responsible for immediately notifying [ORA, Regional Management] and their senior management of any significant EHS inquiry or concern from the community or other external parties. Facility Manager shall be responsible for implementing any action plan developed and approved by [ORA, Regional Management] and their business executives if the Facility is designated to respond to the inquiry or concern.

C.Office of Regulatory Affairs [for facilities in North America]

The Office of Regulatory Affairs (ORA) shall be responsible for submitting certain reports to governmental authorities. RERM and Facility Manager shall work with ORA to ensure correct data is provided to ORA and that reports are timely filed.]

IV.PROCEDURE

The following constitutes the basic principles or rules to be applied to External EHS Reporting and Community Relations:

  1. The RERM shall make a schedule of all reports required to be submitted to governmental entities.
  1. The RERM shall gather all needed information needed for the reports.
  1. The RERM shall coordinate the preparation of any reports and the submission of the report to the governmental agency with [regional management - North America: ORA].
  1. The RERM and the Facility Manager shall be responsible for immediately notifying [ORA and] their regional management of any significant EHS inquiries or concerns from the community or other external parties. The RERM shall be responsible for implementing any action plan developed and approved by [ORA and] their regional management, when responding to such inquiry.
  1. ORA, the Legal Department or senior management shall provide guidance to facilities regarding crisis communications and procedures, including communications with the media.
  1. Facility Manager will insure that only those designated to speak for the Company communicatewith external parties inquiring about EHS issues. All other employees should be instructed not to talk to external parties and should follow the procedure attached as Appendix A.
  1. If a government inspector arrives at the facility, follow the [Company Name/Location] Government Inspection Plan.
V.TRAINING

A.Employee Training

All employees shall receive instruction on this Plan. Training shall be provided:

  1. When there are any changes to the plan and/or facility.
  2. When an employee’s responsibilities change.
  3. Annually as refresher training.

Items to be reviewed during the training include:

  1. The responsibilities of different individuals regarding communication and reporting.
  2. What to do when an outside party contacts you.
  3. What to do if an outside party shows up at the Facility.

B.Training Records

[Responsible Person] shall document all training pertaining to this plan and shall maintain records at Designated Area.

VI.REFERENCES

NCH Policy

VII.APPENDICES

None

VIII.DOCUMENT CONTROL

This External EHS Reporting and Community Relations Plan shall be reviewed annually, or as needed if changes to the worksite are made, by [Responsible Person]. Following each instance of external contact RERM and Facility Manager shall evaluate the response to the inquiry for effectiveness and weaknesses of this Plan, and shall implement changes to improve it.

All changes will be documented and approved in compliance with the Document Management Procedure

Document History:

Procedure version / Date Approved / Approved by / Reason for Change
Date: 23 Month 2009
Version: Draft X / Authorized by: Regulatory Affairs Counsel
Next Review: 23 Month 2010 / Uncontrolled when printed

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References

NCH Policy for External Reporting and Community Relations

1.SCOPE

1.1.Purpose

Community relations activities are intended to enhance and maintain sound relationships with the communities in which NCH operates.

1.2.Applicability

This document applies to all NCH organizations worldwide.

2.POLICY

NCH is committed to effectively working with its neighbors, and others, on EHS matters.

3.STANDARD

The following constitute the basic principles or rules to be applied to External Reporting and Community Relations:

1.Organization managers shall be responsible for immediately notifying ORA and their senior management of any significant EHS inquiries or concerns from the community or other external parties. Organization management shall be responsible for implementing any action plan developed and approved by ORA and their business executives.

2.Organization managers shall ensure that an appropriate spokesperson is designated at each facility to speak with the media and community representatives, as approved.

3.ORA or the Legal Department shall provide guidance to facilities regarding crisis communications and procedures, including communications with the media.

NCH has made a considerable investment in safeguarding the environment and the health of its employees and the public. The strategy has been to meet, and for valid business reasons, exceed legal requirements and increase overall EHS awareness

The ORA Home Page on the NCH Intranet is an additional internal resources for EHS resources and communications. Information found on the ORA Home Page is not intended for public distribution. Check with ORA if you wish to publicize information found on the ORA Home Page Intranet.

Facility Managers shall, as appropriate develop and maintain long-term relationships with local emergency agencies.

  1. Meet your local officials – Identify key personnel for them to contact for inquiries, under the direction of Corporate communications.
  1. Work with local fire departments, by sharing details of Emergency Response Plans.
  1. Maintain sound local working relationships.
  1. Follow action plans developed and approved by ORA and their business executives to address any significant EHS inquiries or concerns from the community or other external parties.

Facility managers shall ensure that an appropriate spokesperson is designated at each facility to speak with the media and community representatives, as approved. Generally, all communications with outside entities should be directed to the Corporate General Counsel or the Corporate Regulatory Affairs Counsel unless otherwise directed by these individuals or Senior Regional Management. If so directed, determine, based on guidance from Corporate General Counsel, Corporate Regulatory Affairs Counsel or Senior Regional Management, who will be the official spokesperson. Some key communication guidance which would be emphasized in communications training would be:

  1. Be prepared: Don’t conduct an interview “on the fly” or “in a rush”
  1. Write down you key points first
  1. Don't speculate
  1. Don't be afraid to say ‘I don’t know’
  1. Be cordial yet professional; keep your cool
  1. Seek advanced approval and counsel from Corporate General Counsel, the Corporate Regulatory Affairs Counsel or Senior Regional Management

Facility Managers shall monitor reaction to communication efforts by conversing with employees and Community leaders and by monitoring media coverage. It may be advisable, for example, to assign specific employees to monitor specific media outlets and report their findings.

Facility Management should insure that only those designated to speak for the Company communicate. All other employees should be instructed not to talk to external parties except as follows:

IF INDIVIDUALS REPRESENTING THEMSELVES AS

NEWSPAPER, RADIO OR TV REPORTERS

CALL OR PRESENT THEMSELVES IN THE LOBBY

  1. ASK WHO THEY REPRESENT (NAME OF NEWSPAPER FOR EXAMPLE) AND WHAT ISSUE THEY WISH TO DISCUSS.
  2. ASK THEM FOR THEIR NAME, POSITION AND RETURN TELEPHONE NUMBER.
  3. TELL THE PERSON THAT YOU WILL CONTACT THE APPROPRIATE PERSON TO HELP THEM AND CALL THEM OR RETURN THEIR CALL. DO NOT SIMPLY TRANSFER THE CALLER TO ANY OF THE PEOPLE BELOW.
  4. DO NOT VOLUNTEER ANY INFORMATION INCLUDING THE NAME OF THE PERSON YOU ARE GOING TO CONTACT IN THE COMPANY.

At the local level, should a crisis or other situation requiring external communication occur (such as a call from the local newspaper about a specific issue), Facility Managers shall immediately contact Corporate General Counsel, the Corporate Regulatory Affairs Counsel or Senior Regional Management for guidance on a general strategy for communicating information before any external response is initiated.

All Facility Managers and other responsible personnel are expected to fulfill the intent as well as the letter of NCH’s EHS policies. NCH expects facility managers to make every effort to prevent incidents or conditions that may result in an EHS crisis.

When an EHS crisis occurs, such as a hazardous spill, a discovery of contaminants in ground water, or a building evacuation because of fumes, a serious injury, the company wants to provide timely and accurate information to interested parties. Facility Managers may be asked by Corporate General Counsel, the Corporate Regulatory Affairs Counsel or Senior Regional Management to provide periodic reports to community residents when a problem occurs. The following steps are provided to guide the Facility in responding effectively if an EHS crisis occurs.

  1. Immediately contact Corporate General Counsel, the Corporate Regulatory Affairs Counsel or Senior Regional Management.
  2. Be prepared to implement the notifications and actions required by the facility Emergency Response Plan, and to have quick access to telephone numbers of local emergency personnel and appropriate NCH corporate and divisional managers, especially EHS legal and insurance representatives.
  3. Review communication source statements or other documents created during communication planning, and secure Corporate General Counsel, the Corporate Regulatory Affairs Counsel or Senior Regional Management approval before use.
  4. Work with corporate representatives to draft new communication documents, such as communications to employees, letters to residents and news releases to the media. Only individuals designated and trained as official company spokespersons may speak to the media on behalf of the company or the facility.
  5. Decide, in conjunction with Corporate General Counsel, the Corporate Regulatory Affairs Counsel or Senior Regional Management, whether to create a repository for public review of technical reports and other documents.
  6. Monitor and report on the community’s reaction by asking employees about what they are hearing, by interacting with community leaders and by monitoring media coverage. Based on the reaction and on the nature of the problem, Facility Managers should work with Corporate General Counsel, the Corporate Regulatory Affairs Counsel or Senior Regional Management to plan and implement subsequent necessary communication activities.

Prior to making a statement in response to a crisis, the responsible person(s) should be able to answer the following, under the direction of Corporate Communications:

  1. What is the nature of the incident?
  2. What response actions have been taken or are planned
  3. Has anyone been injured?
  4. Have government authorities been notified?
  5. What external communications have been taken or are planned?

Appendix A

IF INDIVIDUALS REPRESENTING THEMSELVES AS NEWSPAPER, RADIO OR TV REPORTERS, OR SOME OTHER EXTERNAL PARTY, CALL OR PRESENT THEMSELVES IN THE LOBBY

(2)Ask who they represent (name of newspaper for example) and what issue they wish to discuss.

(3)Ask them for their name, position and return telephone number.

(4)If the person is calling, tell the caller that you will contact the appropriate person to help them and return their call. Do not simply transfer the caller to any of the people below. If the person is present at the location, ask for that person’s phone number and tell the person that you will contact the appropriate person and that someone will call to respond.

(5)Do not volunteer any information including the name of the person you are going to contact in the company.

(6)If the issue concerns the Facility, call:

a.______

b.______

c.______

d.______

e.______

(7)If the issue concerns anything other than the Facility, call:

a. ______

  1. ______

c. ______

d. ______

e. ______

Date: 23 Month 2009
Version: Draft X / Authorized by: Regulatory Affairs Counsel
Next Review: 23 Month 2010 / Uncontrolled when printed

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