Sunoco believes that the company should be organized not only to enable the efficient manufacture and sale of products, but also to encourage ethical behavior at all levels of the corporation.
Auditing Program Sunoco's company-wide Health, Environment, and Safety Auditing Program began in the 1980s and is driven by protocols focusing on the following areas:
The HES audit group also conducts assessments of the Operations Excellence Management System in the Chemicals and Refining & Supply business units. These assessments cover the various elements of OEMS and, in turn, review conformance with the requirements of ACC’s Responsible Care® Management Systems RC 14001 and RCMS, as appropriate. The following elements make up the Plan – Do- Check – Act cycle and are audited:
Plan
Aspect Identification
Expectations
Facility Design
Legal & Other Requirements
Objectives & Targets
Policy
Product Stewardship
Structure & Responsibilities
Training, Awareness & Competence
Act
Management Review
Do
Contractors
Document Control
Emergency Response
Internal & External Communications
Operational Controls
Check
Integrated Audits & Self-Inspection
Monitoring & Measurement
Non-conformance & Corrective/Preventive Action
Records Control
2007 Auditing Activities Sunoco's HES Auditing Group performed 77 compliance audits and assessments at 64 different Sunoco facilities (see table & graphs for breakdown).
HES Audit Cycle
Five refineries and seven chemical plants were audited for the modules shown. 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 one chemical plant.
The HES Auditing Group also conducted Marine security audits as required by U. S. Coast Guard regulations as stipulated by the Marine Transportation Security Act (MTSA). These audits are required annually at locations that have marine transportation facilities.
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Other sites/entities audited included:
Sixteen company-operated convenience stores (Co-Ops) and twenty-four franchise service stations; Six Transportation terminals;
Fourteen management system assessments were conducted (covering five refineries, six chemical plants, two business unit headquarters, two research and technology locations, and the corporate HES professional services and engineering groups) to verify progress with the company's management system; and
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 three pipeline division audits (about 25 locations visited), eight distribution terminals and five MTSA security audits). In addition, three refineries, two chemical plants, and three cokemaking facilities underwent third-party loss prevention reviews.
Audit Team
Sunoco “Guest Auditors” do many practice exercises as part of their two-day training.
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 from Specialty Technical Consultants (STC), 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 among the facilities.
Sunoco HES field and Resource Center personnel must undergo auditing training prior to participating in an audit. In 2007, 22 field auditors attended the two-day Auditor Training course taught by the Corporate HES Auditing Group.
The Sunoco HES Audit Group also trained an additional 38 employees so they can conduct OEMS self-inspections at their facilities.
Audit Findings
Refinery and chemical plant audit teams include third-party auditors hired for their experience and knowledge.
The audits conducted at Sunoco facilities during 2007 resulted in 28 key findings of opportunities for improvement, a 76.4% drop in the number of findings when compared to 2004 (the last time the same topics were audited). The most common findings related to Leak Detection and Repair (LDAR) items, cranes, Hearing Conservation, Respiratory Protection, Industrial Hygiene, and Management of Change as part of Process Safety Management. The audits also point out achievements by the facilities (292 items) as well as suggestions for improved work practices.
Findings Resolution Facilities must develop an action plan, including projected completion dates, to resolve all audit findings not completed within 45 days after issuance of the final audit report. 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 Corporate Responsibility Committee of the Sunoco Board of Directors.
Independent Review Sunoco’s HES Audit Program received an independent review during 2007 as part of the re-certification process for American Chemistry Council (ACC) Responsible Care® Management Systems RC 14001. This audit, conducted by NSF, a third-party audit firm, resulted in no findings of non-conformance.
Additionally, 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 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 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, regulatory non-compliance issues are immediately disclosed to the applicable regulatory agency.
Related Links: Certified Auditors Of Sunoco's five full-time HES Audit professionals, two are Certified Professional Environmental Auditors ... read more
Independent Review An independent review of Sunoco's audit program is conducted every five years ... read more
