Journal Communications, Inc.
Journal Communications, Inc. retained Sigma to benchmark the Environmental, Health and Safety (EHS) performance and develop site specific EHS management systems for JCI business units involved with printing / production located in Wisconsin, Ohio, Florida, Connecticut, Vermont and Minnesota. Sigma also developed EHS compliance guidelines for the non-production facilities for broadcasting and data management.
The assessment process focused on the following key elements with consideration given to normal and abnormal operations and to potential emergency conditions:
- Legislative and regulatory requirements.
- Identification of significant EHS aspects.
- Examination of existing EHS management practices and procedures.
- Evaluation of feedback from the investigation of previous incidents.
The process of evaluating the EHS programs and requirements for the facilities included the following elements:
- Pre-audit preparation – list of documents to be reviewed during the on-site evaluation is provided to the facility to allow them time to prepare.
- Kick-off meeting – brief meeting is conducted the day of the assessment with the audit team and designated facility representative(s) with the intent of reviewing the day’s strategy and addressing any questions or concerns.
- Facility tour – complete tour of the facility is conducted in order to gain an understanding of operations. The objectives of the tour are to:
- develop an understanding of the facility operations with respect to EHS obligations (e.g. chemical usage and storage locations, waste generation and storage, air emissions sources);
- define the applicability and status of environmental programs
- define the applicability and status of health and safety programs
- Records review – following the tour, documents related to EHS programs are reviewed. This may include waste disposal documentation, Material Safety Data Sheets, and correspondence with regulatory authorities.
- Closeout meeting – prior to leaving the facility, a brief meeting are held to provide a verbal summary of initial findings.
Identify Gaps and Report Findings
Results of the EHS program assessment were provided in a Findings Report, which consisted of an Executive Summary, a detailed discussion of the status of each of the individual programs, a gap analysis, and an action item list. Each of the action items was assigned a priority ranking (high, medium, low) in order to assist with the prioritization of addressing items of interest.
Development of EHS Management System
Information obtained during the assessment and summarized in the Findings Report were used to develop an EHS management system to be utilized as a tool for maintaining compliance. The management system consisted of a Compliance and Procedures Manual providing an overview of applicable regulations and requirements and how they affect the individual facility; a calendar of activities and deadlines; and a matrix summarizing rules, requirements, roles and responsibilities.