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Auditing Program
Sunoco's company-wide Health, Environment and Safety Auditing Program began in the 1980s. Since that time it has been modified as auditing techniques and methodologies have changed. As a part of Sunoco's Business Improvement Initiative the audit program

underwent a re-design during 2009.

The re-design focused on utilizing more internal resources and adjusting audit length and frequency to allow the auditors to dig deeper into key HES areas.

The audit program addresses both compliance and management systems auditing. This is done using audit teams led by full-time Sunoco HES Auditors. The audit teams focus on key environmental and safety 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 the Plan – Do – Check – Act cycle of OEMS and, in turn, review conformance with the requirements of ACC’s Responsible Care® Management Systems RC 14001 and RCMS, as appropriate.

2009 Auditing Activities
Sunoco's HES Auditing Group performed 17 compliance audits and assessments at 9 different Sunoco facilities (see table & graphs for breakdown).

Four refineries and three chemical plants were audited along with a headquarters location, cokemaking facility in Brazil, and a pipeline group. Process Safety Management audits were conducted at three refineries.

The HES Auditing Group also conducted four 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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Audit Team
The refinery and chemical plant audits are conducted by teams, led by Sunoco's HES Audit professionals, utilize subject matter experts (SMEs) from the Corporate HES Group and other Sunoco facilities. Using Sunoco SMEs provides the audit team with expertise and promotes an opportunity exchange of information and ideas among the facilities and company experts.

The Subject Matter Experts attend an Auditor Training session, taught by the Corporate HES Auditing Group, prior to participating on an audit.

Audit Findings
The audits conducted at Sunoco facilities during 2009 resulted in 24 key findings of opportunities for improvement. The most common findings related to wastewater handling, air - leak detection and repair (LDAR), electrical safety, Management of Change (MOC), and Process Safety Information (PSI). The audits also point out achievements by the facilities (104 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 periodically reported to senior management.

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.

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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.

An overall HES Audit Program summary is shared annually with both the Sunoco Leadership Team and the Corporate Responsibility Committee of the Sunoco Board of Directors. Additionally, the Vice President, Corporate HES&S Assurance & Regulatory Affairs meets in executive session with the Corporate Responsibility Committee several times during the year.

Independent Review
Sunoco’s HES Audit Program received an independent review during 2009 as part of the surveillance audits for American Chemistry Council (ACC) Responsible Care® Management Systems RC 14001. This audit, conducted by BSI, a third-party audit firm, resulted in no findings of non-conformance.

In the past, Sunoco's HES Audit Group has undergone a thorough evaluation 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).

A review was planned for 2009, however with the re-design of the program we chose to have ERM, who would have conducted the evaluation, be a participant in the re-design. This enhanced the benchmarking of audit programs and enabled input form an independent source.

The results of the previous evaluation (i.e., the 2004 evaluation) can be viewed by clicking here. Overall, the final report stated 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."

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. Regulatory non-compliance issues are reviewed and disclosed to the applicable regulatory agency as required.


Related Links

Certified Auditors
Of Sunoco's full-time HES Audit professionals, two are Certified Professional…

Independent Review
An independent review of Sunoco's audit program is conducted periodically…