3What is ECAP? Environmental Compliance Assessment Program (ECAP) Third Party AuditTeamSmithfield Foods, Inc.Hunton & Williams, LLPERM or Gannett FlemmingProgram is confidential “Attorney Client Privileged” & not for external use outside the company.
4Our MissionTo be a trusted, respected, and ethical food industry leader that excels at bringing delicious and nutritious meat and specialty food products to millions every day while setting industry standards for corporate social responsibility.
5Our Core Values To produce safe, high quality, nutritious food. We will constantly strive:To produce safe, high quality, nutritious food.To be an employer of choice.To advance animal welfare.To protect the environment.To have a positive impact on our communities.
6ECAP Focus Areas Wastewater Storm Water Drinking Water Water Rights AirRCRA Non-hazardous, Hazardous and Universal WasteCommunity Right-to-KnowMaterial ManagementFIFRA PesticidesPolychlorinated Biphenyl (PCB) MaterialsAsbestos - DisposalSuperfundWetlandsLead-based PaintGroundwater Monitoring and Underground Injection WellsRisk Management PlanningMedical WasteSpill Prevention Control and Countermeasure (SPCC) PlanningOSHA’s Hazardous Waste Operations RequirementsRegulated Refrigerant (CFC/HCFC) ManagementEnvironmental Management System PracticesFacility, Food & Bio SecurityGreenhouse Gases
7Why ECAP? Assess Compliance Status Find and correct non-compliance Implement best practicesBenchmark PerformanceTraining MechanismGoal100% Compliance, 100% of the Time!
8When – ECAP Cycle Year 1 – ECAP Year 2 & 3 – OFF Year 4 – ECAP ~Schedule may be adjusted by Smithfield Foods, Inc. for extenuating circumstances.
9ECAP Process Pre-Assessment Questionnaire Site Visit Final draft of Finding & RecommendationsAll ducuments shall be maintained only on the Hunton & Williams workroomDocumentation is not permitted to be transmitted by , fax, & other electronic media.Report & Score (for internal use only)Follow-up (provided as needed)
10Scores from Each Section Average Facility Score: ECAP Scoring AreasEach facility is scored based directly on the number and priority of findingsScores from Each Section% of ScoreI.Wastewater2.0/4.050%II.Storm Water1.0/4.025%III.Drinking Water & Water Rights4.0/4.0100%IV.Air and Regulated Ref. Management3.0/4.075%V.RCRA, Superfund, & PCBVI.Community Right-to-KnowVII.Material Storage & SPCCVIII.AsbestosIX.Risk Management PlanX.Miscellaneousa. Wetlands and waterwaysb. Lead-based paintc. Groundwater monitoringd. Medical wastee. OSHA's Haz. Wst. Op. Requirementsf. FIFRAAverage Facility Score:2.5/4.063%
11ECAP Scoring Criteria 4 Absence of any priority A, B or C findings. 3 Absence of any priority A and not more than one priority B findings.2At least one priority A finding and/or more than one priority B findings.1More than one priority A finding, or at least one significant priority A finding (e.g., missing permit or plan; reportable violation(s)).
24HOW TO “BE PREPARED”!READ YOUR PERMITS & PLANS (e.g., NPDES, Pretreatment, AIR Permits, SPCC Plan or SW3P) and understand WHAT, WHEN, WHO, & HOW is required!MAINTAIN UPDATED & IMPLEMENTED PLANSTRAIN, RE-TRAIN & DOCUMENTMaintain, Document, Communicate & VERIFY!!!Keep detailed and organized filesCommunicate – no surprises, ask for help, follow-up