Coulter Wood, Hormel Foods, Hormel Foods Auditing Program, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

1. Hormel Foods Auditing Program
Coulter Wood, Senior Environmental Engineer, CPEA

2. About Hormel Foods
 Founded in Austin, Minn., in 1891
 20,500 employees worldwide
 $9.3 billion in sales
 More than 30 brands in the No. 1 or No. 2 market share position
 Over 40 manufacturing facilities

3. About Hormel Foods

4. Hormel’s Environmental Audit Program
 PURPOSE:
– Compliance!
• Company policies and practices
• Federal, state and local regulations
• Specific permit conditions
– Provide management with sufficient information
to perform risk-based decisions
– Exchange best practices
– Advancement of environmental knowledge and
training

5.  SCOPE
– Air quality
– Asbestos management
– Drinking water
– Environmental
management systems
– Hazardous materials
– Hazardous waste
– Oil and petroleum
Hormel’s Environmental Audit Program
– Ozone Depleting
Substances (ODS)
– Special pollutants (PCBs)
– Storm water
– Universal waste
– Used oil
– Wastewater

6.  Frequency: 3-5 year for manufacturing facilities
 Audit team: Lead auditor plus 1-3 internal auditors
– Write findings
– Work with facility staff to resolve findings
 Facility staff: Plant engineering plus management
– Facilitate on-site portion of the audit
– Ensure availability of environmental records
– Provide tour
– Resolve findings through corrective action process
Hormel’s Environmental Audit Program

7.  PROCESS
– Initial notification: 4+ weeks in advance
• Create and review audit checklist
• Lead auditor and facility management jointly determine
dates of the on-site portion of the audit
– Pre-audit activities: 2-4 weeks in advance
• Finalize audit team
• Assign program areas to audit team members
• Members review assigned areas (prior audit, permits, etc.)
• Facility informs team of upcoming audit and potential
interviews
• Facility ensures availability of complete environmental files.
Hormel’s Environmental Audit Program

8.  PROCESS cont.
– On-site activities
• Opening meeting
– Review scope
– Specific areas of concern
– Cover any activities of interest taking place during audit
(hazardous waste pickups, inspections, etc.)
• Facility tour
• File review
• Employee interviews
• Periodic summary updates
Hormel’s Environmental Audit Program

9.  PROCESS cont.
– On-site activities
• Prepare audit findings
– Priority 1
– Priority 2
– Repeat
• Closing meeting
– Verbal disclosure of findings to facility staff and management
– Questions or concerns
– Items requiring follow-up
Hormel’s Environmental Audit Program

10.  REPORTING
– Lead auditor prepares audit report
– Facility staff review to request edits or share comments
– Lead auditor incorporates into the audit report
– Final report reviewed by the director of environmental
sustainability
– Final report submitted within 15 working days of field
portion of the audit
– Distribution through vice president of supply chain and
appropriate business unit leaders
Hormel’s Environmental Audit Program

11. The Transition
Internal
questionnaire
External
(commercial)
software
Home grown
software

12. A portion of the
original check list

13. The original
rating sheet
report

14. Struggles with First Internal System
 Findings were hard to define
 Scoring could be subjective
 Reliance on the score
 No corrective action tracking

15. The Switch to a Commercial System
 Largely driven by price
 Internal system given a chance
 Reviewed several vendors and consultants
 From to

16. Pros
 System allowed access to:
–Federal question sets
–State-specific questions
 Provided regulatory updates
 Export to MS Excel
 Paid by number of “seats” or subscriptions

17. Cons
 Annual
pricing
structure
caused
$ $$$$
 Corrective
action
tracking
deficient

18. Cons (cont.)
 Appearance was very basic
 No legitimate audit question
– Eg. Is the facility meeting all of the hazardous
waste handler requirements?
 Information only “questions”
 Regulatory citation inaccuracy

19. The Switch Back to Home Grown
 Needed something to provide regulatory
updates
 The existing QA system was already built –
needed only slight modifications
 Return of the score
 Reduced, but not eliminated, subjectivity

20. Internal Compliance System
(How it Works)

21. Example Question Set

22. Preparing to Publish the Audit

23. Entering Corrective Actions

24. Pros
1. Automation & Simplicity
– Everything is completed in the system
– Email notifications
2. Location-specific audits
– One audit set up for each facility:
• Each has the generic list of federal questions
• PLUS state-specific depending on location
• PLUS plant-specific for permits,
authorizations, etc.

25. Pros
3. Report ready to print once question sets are
complete
– Far less formatting efforts

27. Pros
4. Report ready to print once question sets are
complete
– Far less formatting efforts
5. Links to guidance documents
– Can hyperlink, but have chosen not to due
to changes in the regulations and web sites
6. Tracks corrective actions to closure

28. Cons
 Set up time
 Still need regulatory updates
 Still learning the efficiencies and effectiveness

29. QUESTIONS?