Sunoco's company-wide Health, Environment and Safety Auditing Program began in the 1980s and is driven by protocols focusing on the following areas:

Environmental Spill Prevention Water Quality Air Quality PCB Management Solid/Hazardous Waste Underground Storage Tanks SARA Sections 311, 312, 313

Health & Safety Emergency Planning & Fire Safety Toxic Substances Control Act (TSCA) Personnel Safety Hazardous Materials Transportation Industrial Hygiene Occupational Medicine Materials & Equipment Safety Risk Management Planning/Process Safety Management

Security Marine Transportation Security Act (MTSA)

The HES audit group also conducts assessments of the Operational Excellence Management System in the Chemicals and Refining & Supply business units. These assessments cover the various elements of OEMS and, in turn, reviews conformance with the requirements of ACC’s Responsible Care® Management Systems RC 14001and RCMS, as appropriate.

2005 Auditing Activities
Sunoco's HES Auditing Group performed 87 compliance audits and assessments involving 66 different Sunoco facilities (see table & graphs for breakdown).

Five refineries and six chemical plants were audited for the modules shown below. Audits were also performed at company-operated retail service centers (Co-Ops), transportation terminals, and some business functions (i.e., engineering, etc.). Process Safety Management audits were conducted at three refineries and the racing fuels facility.

The HES Auditing Group began conducting Marine security audits as required by U. S. Coast Guard regulations as stipulated by the Marine Transportation Security Act (MTSA). These audits are required to be done annually at locations that have marine transportation facilities. (Click here for additional information about security.)

Other audited facilities included:

• Thirty company-operated convenience stores (Co-Ops) and ten franchise service stations
• Six Transportation terminals
• Thirteen management system assessments were conducted (covering five refineries, five chemical plants, two business unit headquarters, two research and technology locations, and the corporate engineering group) to verify progress with the company's management system.
• Safety recordkeeping verification, since incident rates factor into the HES portion of the Success Sharing Program.

The Sunoco HES Auditing Group also provided auditing support for Sunoco Logistics Partners L. P. by conducting audits at three pipeline division (24 locations visited) and ten distribution terminals (including 5 MTSA security audits).

In addition, three refineries and three chemical plants underwent third-party loss prevention reviews.

Audit Team
Major facility (refineries and chemical plants) audits are conducted by a team consisting of Sunoco's HES Audit professionals, Corporate HES Resource Center experts, third-party auditors, and Sunoco's HES field personnel. Field personnel are used on the major facility audits to capitalize on their knowledge and expertise in a particular area as well as to promote an exchange of information and ideas between the facilities.

Sunoco HES field and Resource Center personnel must undergo auditing training prior to participating in an audit. In 2005, over 30 field auditors attended the one-day Auditor Training course taught by the Corporate HES Auditing Group.

Audit Findings
The audits conducted at Sunoco facilities during 2005 resulted in 79 key findings of opportunities for improvement. The most common findings related to documentation of process safety management, electrical safety, confined space, lockout/tagout and waste management activities. The audits also point out achievements by the facilities (325 items) as well as suggestions for good working practices.

Findings Resolution
Facilities must develop an action plan to resolve all audit findings not completed within 45 days after issuance of the final audit report. The plan includes projected completion dates. Completion of corrective actions is verified through periodic follow-up audits and through quarterly reports to the Corporate HES Committee.

Sunoco monitors the status of all HES audit findings through its AuditTrack database program for tracking and analyzing HES audit findings. Facilities must report on the status of open audit findings every 90 days until the item is resolved.

Communication of Results
The final report from each HES audit is submitted to the appropriate line manager, facility manager, and executive management for their review and corrective action.

In addition to the quarterly status reports, an overall HES Audit Program summary is shared annually with both the Corporate HES Committee and the Public Affairs Committee of the Sunoco Board of Directors.

Independent Review
Sunoco's HES Audit and Assessment Standard requires that the Audit Program be evaluated by an independent third party every five years. Reviews have been conducted in 1994, 1999 and in 2004. The 2004 review was performed by Environmental Resources Management, Inc. (ERM).

In conducting the 2004 review, ERM reviewed all appropriate audit documents (standards, audit protocols, audit reports, etc.); interviewed auditors, plant personnel, and senior management; and shadowed the auditors at a refinery, chemical plant, and transportation terminal audit.

The improvement areas identified were reviewed with the Corporate HES Committee in October and with the Board Public Affairs Committee in November. Corrective actions were developed for the six improvement opportunities identified and were implemented during 2005.

In the final report ERM concluded that the Sunoco HES Audit Program is "a very sound and rigorous program, explicitly supported by a Corporate Policy, with quality audit reports, and well-developed tracking and closure systems". Click here to see the Sunoco HES Audit Program Evaluation Summary

A Self-Evaluation Tool
Because the audits are comprehensive internal reviews of company operations, their results are not available to the public. Sunoco treats these audits as confidential business information in order to encourage effective and candid self-evaluation. Although rare, non-compliance issues are immediately disclosed to the applicable regulatory agency.

Major 2005 Audit Modules (Major Facility)
	Number of Facilities
Air Quality - Air Combustion Sources	11
Solid/Hazardous Waste	11
Storage Tanks	11
SARA 313	11
Personnel Safety*	11
Hazardous Materials Transportation	5
Process Safety Management	4
MTSA Security	7

* Includes Confined Spaces, Lockout/Tagout, Electrical Safety, Excavation & Trenching, etc.

HES Glossary
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Conversion Table
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Summary Report
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Certified Professional Environmental Auditors (CPEA)
Two of Sunoco's HES Audit professionals are Certified Professional Environmental Auditors...
read more.

The Auditing Roundtable
web site
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