Compliance Assessment On-Site EHS - (Global - English Language)

SectionNo Section QnID Question

Section Number (1, Section Title Question ID Text of the Question

2, 3 etc)

During the last 5 years, has the company been

free of Fine and Violations notices from
Government agencies? If “no,” please provide
1 Site Background 1.1 details.
Is the soil and groundwater at the site free of
chemical contamination? Answer “no” and
provide details if there has been any
investigation or remediation of the soil or water
1 Site Background 1.11 at the facility.

Does the company maintain a written

statement or policy protecting the employees
from discrimination and communicates this
1 Human Rights 1.12 policy to employees at the facility?
Does the company maintain a written
statement or policy protecting the employees
from harassment or retaliation and
communicates this policy to employees at the
1 Human Rights 1.13 facility?

Does the company have an objective process

for handling employee complaints that is
outside the direct supervisory chain of an
employee that might have a concern and is the
existence of the process communicated at the
1 Human Rights 1.14 audit location?
Does the company have a written policy to
allow workers to freely choose whether or not
to lawfully organize and join associations such
as a trade union and communicate this policy
1 Human Rights 1.15 to the employees?
Do other aspects of the facility’s HR
management appear to be well organized and
1 Human Rights 1.16 in compliance with local regulations?
Does the facility have all environmental
permits required to conduct operations at the
1 Permits 1.2 facility?
Does your company have all health and safety
permits required to conduct operations at the
1 Permits 1.30 facility?
Does the facility have all required local fire
1 Permits 1.4 code authorizations?

During the last 5 years has the company

operated without any serious injuries resulting
1 General 1.5 in death? If “no,” please provide details.
 During the last 5 years, has the facility
operated without any serious injuries that
required hospitalization for more than 24
1 General 1.6 hours? If "No," please provide details.
Is the facility located at least 100 meters away
from any schools, nursing homes, daycare
centers, residences, protected natural areas,
or other sensitive uses? If “no,” please provide
1 General 1.7 details.
Does the facility conduct fire drills at least
1 Emergency Prep 1.8 annually for all shifts?
Does the facility test the emergency alarm
1 Emergency Prep 1.9 systems at least every six months?
Do the employees look to be above the
minimum local legal age limit or 16 years old,
2 On-Site Review 2.1 whichever is higher?
Are the work areas kept at a reasonable
2 On-Site Review 2.1 temperature?
Are all chemicals and wastewater managed or
treated (e.g. neutralized or processed) as
required by local law or site permit prior to
going being discharged to a sewer or drainage
2 On-Site Review 2.11 system?
Are all waste materials, scrap materials or
garbage stored on concrete or a paved area?
2 On-Site Review 2.12 If “no,” please provide details.
Do all drums and other storage containers of
raw materials, supply chemicals or work in
progress appear in good condition, stored in
2 On-Site Review 2.13 contained areas & well managed?
Does the vegetation on site appear to be
2 On-Site Review 2.14 normal for the area and the season?
Are air emissions ordinary in appearance and
odor (for example, not visibly dark or strong
2 On-Site Review 2.15 yellow color or with a strong odor)?
Are waterways near to the site free of
discoloration, sheen, and debris from the
facility, particularly near the site’s water
2 Water 2.16 discharge points?

Does the facility have appropriate medical

2 Emergency Prep 2.17 emergency response equipment and supplies?

Is there an alarm system to notify employees

2 Emergency Prep 2.18 of an emergency situation in all work areas?
Are there fire extinguishers or firefighting
equipment in all areas of the facilities that are
easily accessible and have been inspected
2 Emergency Prep 2.19 within the last twelve months?
Do the employees appear to be present
2 Human Rights 2.2 voluntarily?
 If the facility has a canteen or a cafeteria, is
the area clean and is food prepared, stored,
2 Working Conditions 2.2 and served in a sanitary manner?
Are employees using eye protection in areas
where there is a risk that chips/ particles may
be flung from the machinery or they could be
2 Working Conditions 2.22 splashed with chemicals?
Are machines guarded so that employees
cannot reach into machines with rotating or
moving parts, or under or into devices that
2 Working Conditions 2.23 stamp, cut or punch metal?
Are employees wearing shoes appropriate for
2 Working Conditions 2.24 a manufacturing environment?
Are workers wearing hearing protection in
2 Occupational Health 2.25 areas where noise is very loud?
Are employees in chemical processing areas
(e.g. painting, plating, or chemical cleaning,
visible dust or visible vapor) using appropriate
2 Occupational Health 2.26 breathing protection?

2 Working Conditions 2.27 Does all wiring appear to be in good condition?

If lifting devices (cranes, forklifts, chains and
slings) are used on site, is the weight rating
readily visible and are written maintenance
2 Working Conditions 2.28 records of the lifting device up to date?
Does the site have an effective process to
ensure that it is in compliance with the
2 Occupational Health 2.29 chemical restrictions in GEs PO?
Can the employees freely exit the facility when
2 Human Rights 2.3 they are not working?
Are material safety data sheets (MSDSs) for all
chemicals used on site available to employees
2 Occupational Health 2.3 for their use?

Are all chemicals stored properly, in specially

designated areas, and in good condition
containers (included drums, tanks, etc.) that
are clearly labeled with their contents and
2 Occupational Health 2.31 hazards in the local language?
Are all waste storage containers, including
drums, stored in contained areas, well
2 Waste 2.32 managed, and appear in good condition?

Does the work place and the equipment used

within the manufacturing area appear to be
maintained and utilized with safety devices,
safeguards, and proper work practices,
methods, processes, which are reasonably
adequate to make the workplace safe? If you
have not already created a finding for your
observation, select "no" and write a detailed
2 EHS 2.34 finding description.
 Does the facility have at least two clearly
designated emergency exits equipped with
crash bars on each floor with a travel distance
of no more than 60 meters from any work
2 Emergency Prep 2.4 area?
Are there clearly marked emergency exits that
are visible from all corridors, staircases, and
2 Emergency Prep 2.50 aisle ways?
Is the general housekeeping of the facility
2 Working Conditions 2.6 good?
2 Working Conditions 2.7 Does the facility have good lighting?

2 Working Conditions 2.71 Is clean drinking water provided in the facility?

Is the facility free of visible haze/chemical mist
or dust in the shop works areas? If “no,”
2 Chemical Mgmt 2.8 please provide details
Is the facility free from objectionable odors in
2 Chemical Mgmt 2.9 the indoor work areas?
Housing Facilities Are employees allowed to live outside
3 Review 3.1 company-provided housing?
If food preparation is occurring in common
areas: are all cafeteria or kitchen areas clean
Housing Facilities and is food prepared, stored, and served in a
3 Review 3.1 sanitary manner?
Housing Facilities Is clean drinking water provided in the housing
3 Review 3.11 building?
Housing Facilities Is water provided for toilets and bathing in the
3 Review 3.12 building?
Housing Facilities If the climate is cold in the winter, is the
3 Review 3.13 building heated in the winter months?
Housing Facilities Is the building adequately lit when occupied,
3 Review 3.14 both inside and out?
Is the dormitory building more than 100 meters
from activities that might create an adverse
Housing Facilities health and safety impact for employees living
3 Review 3.15 in the housing?

Aside from any issues identified by one of the

other questions, do activities in the housing
appear to be conducted in a safe manner? If
Housing Facilities you see any conditions you think are unsafe,
3 Review 3.16 please answer "No" and provide details.
Housing Facilities Can employees freely enter or leave the
3 Review 3.2 housing at all times of the day or night?
Is the housing clean, especially in the common
Housing Facilities areas such as hallways, toilets and bathing
3 Review 3.3 facilities?
Is there an alarm system to notify employees
Housing Facilities of an emergency situation that is tested every
3 Review 3.4 6 months?
 Are there fire extinguishers in the facilities that
Housing Facilities are easily accessible and inspected within the
3 Review 3.5 past twelve months?
Housing Facilities Are there at least 2 clearly marked routes of
3 Review 3.6 exit from every floor?

Are all stairwells and emergency exits

Housing Facilities unobstructed and unlocked so that employees
3 Review 3.7 can freely exit the building in an emergency?
Housing Facilities
3 Review 3.8 Is there working emergency lighting?
Housing Facilities
3 Review 3.9 Does all wiring appear to be in good condition?

Has the supplier given assurances that it does

not employ vocational school students under
Labor-Wage and the age of 16? If not, please explain
4 Hour 4.1 circumstances in the section provided below.
Did all of the employment records you
reviewed show that employees were at or
Labor-Wage and above the minimum working age or 16 years
4 Hour 4.1 old, whichever is higher?

If the supplier uses vocational students, does

the payment documentation (either by the
Labor-Wage and employer or the school) confirm the students
4 Hour 4.12 were paid at least the minimum wage?

Did all of the employment records you

reviewed show payments at or above the
minimum wage? If any of the employment
records you reviewed showed payments below
Labor-Wage and the minimum wage please answer "No" and
4 Hour 4.2 provide details.

Did all of the employment records you

reviewed show hours of service at or below the
maximum allowable overtime? If any of the
employment records you reviewed showed
hours of service above the maximum allowable
Labor-Wage and overtime please answer "No" and provide
4 Hour 4.3 details.

Did all of the employment records you

reviewed show payment of the required
premium wages for overtime work? If any of
the employment records you reviewed showed
a failure to pay the required premium wages
Labor-Wage and for overtime work please answer "No" and
4 Hour 4.4 provide details.
Did all of the employment records you
Labor-Wage and reviewed show no excessive deductions from
4 Hour 4.5 wages? If "no," provide details.
 Did review of wage payment records reveal
that employees are paid on a current basis or
Labor-Wage and paid not more than one payroll cycle in
4 Hour 4.60 arrears?
Are employees allowed to retain their
employment and other relevant documents
Labor-Wage and (e.g. ID card, etc.) after initial review by the
4 Hour 4.7 supplier?
Did the amount paid to each employee as per
Labor-Wage and payroll records match the cash/bank records
4 Hour 4.8 for the money transfer?
Did the working hours declared in the payroll
Labor-Wage and records match the timesheet for the
4 Hour 4.9 workshop?
Security Mgmt Are/will container-load shipments to GE be
5 Systems 5.32 properly protected?
Security Mgmt Are less-than-container load shipments
5 Systems 5.34 adequately protected?
Security Mgmt Is shipping documentation controlled to ensure
5 Systems 5.36 accuracy and prevent alteration?
Are the company's information technology
Security Mgmt applications protected from improper use or
5 Systems 5.37 alterations?
Does the company conduct employment
screening of employees, including application
Security Mgmt verifications and background checking to the
5 Systems 5.41 extent permitted by law?
Does the company have a process to restrict
unauthorized access to the facility, including
shipping, loading dock and cargo areas, where
Security Mgmt goods are manufactured or stored for
5 Systems 5.43 shipment to GE?

Are there controls to prevent the introduction

of unmanifested materials into shipments of
goods to GE while in the custody of any carrier
Security Mgmt selected by your company prior to delivery to a
5 Systems 5.46 carrier selected by GE?
Does the company have an official who is
responsible for security? Please provide the
Security Mgmt security manager’s name and contact
5 Systems 5.47 information in the details

Does the company have a documented

process for notifying the appropriate personnel
if unsafe or suspicious activities are detected
that includes an established reporting chain,
Security Mgmt time limits for reporting and that extends to
5 Systems 5.48 sub-contractors that handle freight?
 Does the company have a documented
program for education of employees in security
awareness that includes the recognition of
internal conspiracies, maintenance of cargo
Security Mgmt integrity, and addressing unauthorized
5 Systems 5.49 access?

Are there controls to prevent the introduction

Security Mgmt of unmanifested materials into shipments of
5 Systems 5.5 goods to GE while at the facility?

Please go to next tab to review the KPI

evaluation, follow the questions so a KPI
Survey is completed as part of the audit
6 KPI Survey 6.1 process.
lish Language)
Finding Category Remarks

Cross-Reference Category Remarks

Other Environmental

Waste Disposal

Discrimination

Harassment

Dispute Resolution

Labor Rights

Labor Rights

Environmental Permits

Health and Safety Permits

Fire Protection

Other Safety
Other Safety

Other Safety

Fire Protection

Fire Protection

Age

Working Conditions

Waste Disposal

Waste Disposal

Chemical Storage

Waste Disposal

Waste Disposal

Waste Disposal

Other Safety

Emergency Alarms

Fire Protection

Involuntary Labor
Working Conditions

PPE

Machine Guarding

PPE

PPE

PPE

Electrical Safety

Other Safety

Other Environmental

Fire Protection

Other Environmental

Chemical Storage

Waste Disposal

EHS
Fire Protection

Fire Protection

Working Conditions
Working Conditions

Working Conditions

Working Conditions

Working Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Living Conditions

Dormitory Emergency Alarms

Dormitory Fire Prevention

Dormitory Fire Prevention

Dormitory Fire Prevention

Dormitory Fire Prevention

Dormitory Electrical Safety

Age

Wages

Wages

Wages

Working Hours

Wages

Wages
Involuntary Labor

Involuntary Labor

Wages

Wages

Security

Security

Security

Security

Security

Security

Security

Security

Security
Security

Security

KPI Survey
KPI Survey
Category Section Question
A. Environment
Environmental A.1 Is there a person professionally
Management trained in Environment Management
employed at, or supporting, the
company/facility?
Environmental A.2 Does the facility have a process to
Management identify changes that can potentially
impact its EHS compliance, and a
system to make sure that EHS
compliance is maintained during and
after the change is completed?
Environmental A.3 Has a third party audit and/or
Management inspection been performed at the
site in the last 2-3 years to verify
compliance with regulatory
environmental requirements?
B. Labor and Employment
Guidenotes
The facility should have one person
responsible for and expert in environment
regulations and management systems.
Depending on the size or complexity of the
facility, the job can be part-time or shared
with other activities.
Changes in equipment, processes and
activities have the potential for adverse
effects and impact EHS compliance. The
Management of Change (MOC) process
aims to identify and evaluate workplace
hazards (and related impacts to EHS
compliance) whenever new substances,
processes, procedures or equipment are
introduced into the facility. Some examples
of these changes (and associated impacts)
include: new chemical material use in
production (may require this new material
to subsequently be monitored and/or
controlled in wastewater effluent or air
emission points per regulation); and new
construction activity (may require the
facility to obtain permits related to building,
air pollution control, stormwater,
wastewater, etc.). Such changes may also
trigger a requirement to revise an
operating license or environmental impact
assessment (EIA).
The environmental audit refers to
verification of compliance with legislation
requirements. The audit should be
conducted by a third party (e.g. a
consultant, representatives from the
government of the parent company,
environmental authorities, etc.). Along with
audit reports, a status report on all findings
(% complete, actions planned to close
remaining items) should be available.
Labor B.1 Does the site have a process for As minimum core standards, the site
Management staying in compliance with local should retain an identified, trained human
Systems labor and employment law resource expert who understands the
requirements? applicable labor and employment
regulations, is responsible for ensuring
wage and hour compliance and possesses
the authority to ensure worker safety rules
are complied with. In addition, there should
be postings or other means of
communication for employees to be made
aware of basic wage and hour information,
additional labor and employment rights,
worker safety standards and a governance
process for raising issues.

C. Health and Safety

Health and C.1 Is there a person professionally The facility should have one person
Safety trained in health and safety responsible for, and expert in, health and
Management employed at or supporting the safety regulations and management
company/facility? systems. Depending upon the size or
complexity of the facility, the job can be
part-time or shared with other activities.

Health and C.2 Has the facility conducted an overall Risk assessment is the process of
Safety site review to identify and document evaluating risks to workers’ safety and
Management the health and safety risks to the health from workplace hazards. It is a
facility, equipment and employees? systematic examination of all aspects of
work that considers: (1) what could cause
injury or harm; (2) whether the hazards
could be eliminated and, if not; (3) what
preventive or protective measures are, or
should be, in place to control the risks. At
a minimum, this assessment should cover
machine hazards, chemical hazards,
ergonomic hazards and facility risks. The
system should use a formal hazard
evaluation methodology such as Safety
Risk Assessment (SRA), Job Safety
Analysis (JSA), Job Hazard Analysis (JHA)
or Failure Mode and Effect Analysis
(FMEA) to identify hazards and applicable
regulatory requirements.
Health and C.3 Have risks identified in the overall To keep workers safe, communication is
Safety site review been communicated to essential. Workers must know about the
Management employees in a systematic way? risks they face, the prevention measures
being taken and any emergency action
plans. This information should be provided
in clear, non-technical language that will
be easily understood. The facility should
have a system to communicate the
hazards in operation to the affected
employees. The system can be web-
based, communicated during meetings or
one-on-one discussions or physical
postings (i.e. JSA, MSDS, IH results).

Health and C.4 Has a Health & Safety (H&S) audit The audit should be conducted by a third
Safety been performed at the site in the last party (e.g. a consultant, representatives
Management 2-3 years? from the government of the parent
company, etc.). Along with audit reports, a
status report on all findings (% complete,
actions planned to close remaining items)
should be available.

Health and C.5 Has an Occupational Health or Occupational Health or Industrial Hygiene
Safety Industrial Hygiene (IH/OH) (IH/OH) assessment reports should be in
Management assessment been performed at the place. These should include actual
site in the last 2-3 years? qualitative and/or quantitative
measurements. Ask for status of all
findings (% complete, actions planned to
close remaining items).

Health and C.6 Are corrective actions identified by Does the site have a process for tracking
Safety the Environmental, H&S or IH/OH closure of findings? If yes, describe.
Management audits and assessments tracked to
closure?

Health and C.7 Can the site demonstrate that it is in Site should provide documentation that
Safety compliance with a training plan? affected employees are trained on specific
Management environmental regulatory content and the
date that the training was completed.
Health and C.8 Does the facility have a process to
Safety train employees on new or changed
Management EHS hazards or compliance
requirements after changes are
made to the facility and production
process?
Health and C.9 Does the facility have a written
Safety Emergency Preparedness Plan that
Management includes responses for all potential
emergencies that may take place
onsite? Has the facility reached out
to the local authorities to have an
understanding of potentially
extreme emergencies that may
occur at their facility or local to
ensure they are incorporated into
the plan? Has the plan been
communicated to all employees and
personnel that enter the operation
so that all personnel are aware of
their responsibilities for all potential
occurrences under the plan? Has
the facility conducted emergency
drills to ensure the plan is working
properly and addresses all impacted
areas?
D. Security
When changes are made to the facility or
production process/equipment--or new
equipment, chemicals or processes are
introduced to the facility--the employees
should be retrained on the hazards and
risks of the materials and processes.
The Emergency Preparedness Plan
should include responses for all potential
emergencies and extreme emergencies
that may take place onsite for example:
Fire, spills, releases, weather-related
emergencies such as tornados, or
hurricanes/tropical storms, flooding,
earthquakes, tsunami, civil strife, impacts
from neighboring plants and transportation
routes/systems near the plant (rail,
highways, airports). The emergency plans
must be communicated to all employees
and personnel that enter the operation and
all personnel must be aware of their
responsibilities for all potential
occurrences under the plan. Drills should
be conducted quarterly and should be
conducted at a minimum of 1 time per year
to ensure the plan is appropriate and
working as designed.
These requirements may be verified,
through document review, an operation
tour, and interviews with employee that a
program exists and addresses the types of
emergencies possible at the operation.
Security D.1 Does the company have an official In addition to having a company employee
Management who is responsible for security? whose responsibilities specifically include
Systems oversight of the company’s security
practices and procedures, the employee’s
security responsibilities should be
embodied in a position description or other
written document. The employee’s security
responsibilities may be full-time or part-
time responsibilities, may be at the level of
individual plant or shipping locations or
may encompass more than one shipping
location, provided that one or more
employees is responsible for all locations
manufacturing or shipping goods to GE in
the United States.

Security D.2 Does the company maintain written Written procedures should cover access
Management Supply Chain Security procedures? control, physical security, training and
Systems threat awareness, breach reporting,
container and seal security, employee and
transportation provider screening

Security D.3 Does the company have a program
Management for education of employees in
Systems security awareness that includes the
recognition of internal conspiracies,
maintenance of cargo integrity and
addressing unauthorized access?
Illustrative measures include (1.) training
logs to include number of people trained
and their job category; and (2.) training
calendar with names of courses and dates
of training

Security D.4 Does the company have procedures Procedure in place should include (1.)
Management for notifying the appropriate established reporting chain, including
Systems personnel if unsafe or suspicious notifying GE if any potential security issue
activities are detected? or breach involves GE shipments; (2.) time
limits for making reports (no more than 24
hours); and (3.) reporting requirement
applicable to any sub-contractors that
handle freight
Security D.5 Are there controls to prevent the Procedure in place should include (1.)
Management introduction of unmanifested restriction of physical access to goods
Systems materials into shipments of goods to while in the production and shipping
GE? process; (2.) external dock and warehouse
doors secured; (3.) supervision of loading
and unloading of cargo; (4.) checks of
proper marking, weights and numbers of
shipments against invoices or manifests;
(5.) inspection of seals; (6.) use and
inspection of shrink-wrap or other tamper-
proof or tamper-evident forms of
packaging

Security D.6 Does the company have a process Illustrative measures include (1.)
Management to assess their supply chain security identification of high-risk vendors and
Systems risks and implement corrective countries; (2.) identification of all parties in
actions when security gaps are supply chain; (3.) documented Supply
found? Chain Risk Assessment process; and (4.)
surveys, questionnaires and/or on-site
audit reports of vendors, carriers and other
parties in their supply chain.

E. Energy and Water

Energy E.1 Does the supplier track energy Facility should track its energy use (should
Management usage, and have an energy include use of electricity, oil, natural gas,
reduction plan? etc.), and information should be retained
for future use. Costs should be verified as
being accurately tracked. In addition, the
facility should implement projects to
reduce energy usage, ensure that
published goals are in place and that
progress towards those goals are tracked.

Water E.2 Does the supplier track water usage, Facility should track its water use, and
Management and have a water reduction goal? information should be retained for future
use. Costs should be verified as being
accurately tracked. In addition, the facility
should implement projects to reduce water
usage, ensure that published goals are in
place and that progress towards those
goals are tracked.

F. Chemicals & Waste

Chemicals F.1 Doess the site(s) being reviewed
Management have immediately available a
comprehensive list of checmical
substances (chemical products,
mixtures, preparations, alloys, other
component materials) it
manufactures, imports, processes
and/or uses?
Environmental Waste Management Control
Management
G. Permits
Awareness of chemicals, their hazards,
and expected Risk Management Measures
at the workplace should be in place. This
is best achieved by:
1.) Keeping an inventory of all chemical
substances (by virtue of their presence in
chemical products, mixtures, preparations,
alloys, other component materials) made
at, brought to (including imported to), or
intended to be used at, the workplace. A
chemical inventory list typically contains
the following minimal elements: (1.)
chemical name; (2.) Common/Trade
Name; (3.) Manufacturer; (4.) Estimated
Typical Quantity on Hand; (5.) Frequency
of Use; (6.) MSDS availability and its
location; (7.) Emergency Procedure
Required (if any).
2) Having a functioning Chemical Approval
Process (a form of MOC) where changes
driven by functions like Facilities,
Engineering, Product Design, Other are
reviewed and approved (or denied) prior to
use on site.
Ensure Process in place to control waste
management(collecting, treatment,
disposal, recycle) not exclusive for the
supplier/manufacturer alone
Permits G.1 Does the site have a process,
including a named responsible
person, to ensure it keeps track of
regulatory developments and/or
updates that may impact
environmental permits or compliance
at the site?
Permits G.2 Was the site able to show you a list
and an organized file of all current
permits and correspondence with the
authorities regarding regulatory
compliance?
Permits G.3 Was the site able to show you
copies of all current EHS permits
and related correspondence with the
authorities?
The facility should have a dedicated EHS
staff member, lawyer, external EHS
consultant, etc. who continuously monitors
existing and emerging regulations, laws,
statutes, ordinances, etc. to ensure that
such changes will not adversely affect
environmental permits the site presently
maintains. For example, a sewer
discharge authority intends to reduce the
Total Suspended Solids (TSS) limit from
100 mg/L to 50 mg/L by July 1, 2009. The
site's sewer permit presently has a TSS
limit of 100 mg/L. There should be a
process to ensure that announcement of
this newly modified regulatory requirement
is immediately recognized by the facility
and allows the facility to then plan to
achieve this new limit by the required
implementation date.
The facility should develop a list of all
permits given to the site, along with list of
permit conditions that is either written or
referred to on the permit.
The facility should maintain an organized
document filing/retention system
consisting of all supporting documents
corresponding to the site's permits. For
example, a site may have submitted a
wastewater permit application in advance
of receiving an issued permit by the
authority. The facility should maintain on
file a copy of the permit application that
supported the final permit. Another
example is when a facility has an existing
permit and submits a request to use
(discharge) a new material. The agency
approves this request via a letter. A copy
of the letter should be available in the file
to document that the new material
use/discharge is authorized.
Permits G.4 Have all wastewater and air A thorough survey of all plant equipment
emissions sources been identified and operations should be conducted to
and documented? assure that all wastewater and air
discharge/emission sources have been
identified. A unique discharge/emissions
source identification number should be
assigned to each. This identification
number should be consistent with any
numbers that have been assigned in
permits or registrations. Note that for air
emissions, refrigerant-containing
equipment or halon systems should also
be identified as regulated components and
included in your inventory, even though
these components do not normally have
emissions to the atmosphere.
 Score 10 Score 8
A fully trained individual, with an Person is identified and
external certification from a credible fully trained, but not
institution, is assigned as externally certified
environmental leader.
Site has a comprehensive written Site has a comprehensive
procedure requiring EHS review of all written procedure requiring
changes, with responsibilities specified EHS review of all changes,
and a tollgate process. Facility can with responsibilities
produce written evidence of the specified and a tollgate
utilization and implementation of the process
MOC procedure
Evidence provided shows that a Evidence provided shows
certified or governmental third party that a certified or
conducted a comprehensive governmental third party
environmental assessment within the conducted a
last 2 years, and that a process to track comprehensive
and close findings is in place environmental assessment
within the last 3 years, and
that a process to track and
close findings is in place
Score 5
Person has been
assigned and received
some training only (not
comprehensive)
Site has a written
procedure requiring
review of capital
expenditures with EHS,
but no specificity on
timing or systematic
coverage of changes
Site reports that it has
had a third party
environmental audit within
the last 3 years, but is
unable to provide a copy
of the report and closure
documents
(1) Compliant labor and employment
policies have been developed, (2) an
HR Organization has been effectively
developed at the worksite, (3)
Previous labor findings at the site have
been resolved through systemic
corrective/preventive actions; plus (4)
Implementation of HR Management
System (developed HR
rules/handbook, proper employee
documentation, HR orientation and
labor communication, etc.) and (5) HR
staff conducts timely (e.g. quarterly)
labor compliance self-assessment for
the worksite (6) Dispute resolution
system is fully responsive and effective
in the worksite
and (7) Progress reports to
management are made on a regular
basis.
Person is identified and fully trained,
with external certification from a
credible institution
Facility has reviewed its procedures,
identified its high risk processes plus
(1) Facility has identified protective
measures for all employees facility and
(2) has performed JSAs (or equivalent)
on 100% of equipment and processes
(1) Compliant labor and
employment policies have
been developed, (2) an
HR Organization has been
effectively developed at
the worksite and (3)
Previous labor findings at
the site have been
resolved through systemic
corrective/preventive
actions; plus (4)
Implementation of HR
Management System
(developed HR
rules/handbook, proper
employee documentation,
HR orientation and labor
communication, etc.) and
(5) HR staff conducts
timely (e.g. quarterly) labor
compliance self-
assessment for the
worksite
Person is identified and
fully trained, but not
externally certified
Facility has reviewed its
procedures, identified its
high risk processes plus
(1) Facility has identified
protective measures for all
employees (2) facility has
performed JSAs (or
equivalent) on all high-risk
equipment and processes
(1) Compliant labor and
employment policies have
been developed, (2) an
HR Organization has
been effectively
developed at the worksite
and (3)
Previous labor findings at
the site have been
resolved through
systemic
corrective/preventive
actions
Person has been
assigned and has
received some training
only (not comprehensive)
Facility has reviewed its
procedures, identified its
high risk processes plus
(1) Facility has identified
protective measures for
all employees (2) Facility
has started to introduce
JSAs or similar tools
Facility has a well-structured strategy to
communicate health and safety (H&S)
risks to employees, including face-to-
face training, placards, JSAs, MSDSs
and web-based training. Evidence of
the above is visible in the facility (e.g.
bulletin boards, designated safety
signage, etc.). interviews of a sampling
of employees indicates they can
describe and demonstrate the safety
measures they've been trained to take
Evidence provided shows that a
certified or governmental third party
conducted a comprehensive H&S
assessment within the last 2 years, and
that a process to track and close
findings is in place
Site is able to provide evidence of an
external IH/OH assessment within the
last 3 years, with strong evidence of a
monitoring program with follow-on
actions if over-exposure is identified
plus: evidence of a robust employee
protection program, including
monitoring, training and periodic
external reviews
Site has an electronic finding tracking
system, with strong evidence that all
findings are captured in the system and
closed in a timely manner for all 3 of
the following categories:
Environmental; H&S; or IH/OH
Site has a well documented training
plan, is able to demonstrate how
training requirements were identified for
each employee and can show
execution of the plan for all employees
Facility has a well-
structured strategy to
communicate health and
safety (H&S) risks to
employees, including face-
to-face training, placards,
JSAs, MSDSs and web-
based training. Evidence
of the above is visible in
the facility (e.g. bulletin
boards, designated safety
signage, etc.) and (based
on a representative
sampling of the
employees) most of the
employees sampled are
knowledgeable about the
risks.
Evidence provided shows
that a certified or
governmental third party
conducted a
comprehensive H&S
assessment within the last
3 years, and that a
process to track and close
findings is in place
Site is able to provide
evidence of an external
IH/OH assessment within
the last 3 years, with
strong evidence of a
monitoring program with
follow-on actions if over-
exposure is identified
Site has an electronic
finding tracking system,
with strong evidence that
all findings are captured in
the system and closed in a
timely manner for 2 of the
following categories:
Environmental; H&S; or
IH/OH
Facility has used some
mechanisms to
communicate risks and
(based on a
representative sampling
of the employees) most
(>80%) of the employees
sampled are
knowledgeable about the
risks.
Site reports it has had a
third party H&S audit
within the last 3 years, but
unable to provide a copy
of the report and closure
documentation
Site is able to provide
evidence of an external
IH/OH assessment within
the last 3 years, with
evidence that protective
measures have been
taken, but no monitoring
program in place
Site has an electronic
finding tracking system,
with strong evidence that
all findings are captured
in the system and closed
in a timely manner for 1 of
the following categories:
Environmental; H&S; or
IH/OH
Site has evidence of
training plan
Facility has a written process to update
employee training after changes are
made, and is able to provide
documentation of updated training after
a recent change plus based on
representative sampling of select
employees, 100% can explain the
process and how they input into the
updated training
The facility has a written
comprehensive plan that addresses all
of the potential emergencies that may
occure on site or locally or within the
region. The plan has been
communicated to all affected
employees, and they are aware of their
responsibilities and how to respond if
needed. Some elements of the plan
are drilled quarterly and an evacuation
or scenario based drill has been
conducted at least 1 time per year to
determine the effectiveness of the
plan. The site has worked closely with
the community's local emergency
planning organization to ensure that all
potential risks, especially for extreme
events, have been identified, evaluated
and addressed in the plan.
Facility has a written
process to update
employee training after
changes are made, and is
able to provide
documentation of updated
training after a recent
change plus: based on
representative sampling of
select employees, at least
50% are knowledgeable
on the process
The facility has developed
an emergency response
plan that addresses most
of the potential
emergencies (fire, spill,
release, weather-related
emergencies) that may
occur on site or impact the
facility. The employees
are able to communicate
their responsibilieties
during potential
occurances. The facility
has conducted a drill of
most aspects of the plan,
including evacuation,
within the last 12 months.
Facility has a written
process to update
employee training after
changes are made, and is
able to provide
documentation of updated
training after a recent
change
The facility has developed
an emergency response
plan that addresses the
basic potential
emergencies (fire, spill,
release) that may occur
on site or impact the
facility. The employees
are able to communicate
their responsibilieties
during potential
occurances. The facility
has conducted a drill of
most aspects of the plan,
including evacuation,
within the last 12
months.
Person is identified and fully trained Person is identified and Person has been
and has received external certification fully trained but not assigned and has
from a credible institution externally certified received some training
only (not comprehensive)

Security procedures are in place and
defined in writing, have been updated
within the last 12 months,
communicated to personnel on site,
and training records exist
All ssecurity procedures
are in place and
documented, but they
have not been reviewed
within the last 12 months
and/or no training records
exist
Most (>80%) Security
procedures are in place,
but are missing one or
more sections listed in
guidenotes.

Records support that employees are Records support that
trained based on job description; 100% employees are trained
of refresher training up to date based on job description,
with up to 75% of refresher
training up to date
Records support that
employees are trained
based on job description,
with up to 50% of
refresher training up to
date

Business has a documented process Business has an Business has a process

for reporting suspicious activities that
includes an established reporting chain,
including notifying GE if any potential
security issue or breach involves GE
shipments, time limits for making
reports (no more than 24 hours) and
reporting requirements applicable to
any sub-contractors that handle
freightprocedures are well-documented
and current
undocumented process for for reporting suspicious
reporting suspicious activities and it is
activities that includes an communicated to
established reporting employees, but not to
chain, including notifying third parties (vendors,
GE if any potential security suppliers)
issue or breach involves
GE shipments, time limits
for making reports (no
more than 24 hours) and
reporting requirements
applicable to any sub-
contractors that handle
freight
All 6 illustrative measures are in place
and there is evidence that they are
periodically tested
There is evidence that a third party
conducted a comprehensive security
assessment within the last 2 years, and
copy of the closure documentation is
available for review plus: there is
evidence that any findings from the
assessment have been closed
Supplier/site tracks energy use, costs
can be verified, and the site has a goal
to reduce energy usage plus: a budget
and program to meet energy reduction
goal is in place. The site has published
evidence of energy usage against its
internal targets within the last 12
months using an established reporting
method (ie, CDP, WRI/WBCSD or local
compliance reports)
Supplier/site tracks water use, costs
can be verified and the site has a goal
to reduce water usage plus: there is a
documented budget and program to
meet the water reduction goal. The
site has published evidence of water
usage against its internal targets within
the last 12 months using an
established reporting method (ie, CDP,
WRI/WBCSD or local compliance
reports) facility's stated plan (ie, not
through business contraction). Facility
understands the source of their water
and if in a water scarce area, has a
strategy for continued operations in the
event water usage is restricted.
All 6 illustrative measures
are in place
There is evidence that a
third party conducted a
comprehensive security
assessment within the last
2 years, and copy of the
closure documentation is
available for review
Supplier/site tracks energy
use, costs can be verified,
and the site has goal to
reduce energy usage plus:
a budget and program to
meet energy reduction
goal is in place
Supplier/site tracks energy
use, costs can be verified
and the site has a goal to
reduce water usage plus a
budget and program to
meet water reduction goal
is in place
At least 4 of the
illustrative measures are
in place
There is evidence that the
site has conducted an
internal audit/risk
assessment in the last 2
years, and copy of the
closure documentation is
available for review
Supplier/site tracks
energy use, costs can be
verified, and the site has
goal to reduce energy
usage
Supplier/site tracks
energy use, costs can be
verified and the site has a
goal to reduce water
usage
Site(s) maintains a complete inventory Site(s) maintains a
of its raw materials and chemicals used complete inventory of its
on site, and has MSDS sheets for all raw materials and
chemicals (including any in process chemicals used on site,
and manufacturing, maintenance and and has MSDS sheets for
contractor use such as cleaning crews) all chemicals (including
plus: facility has a tollgate to control any in process and
introduction of new chemicals, which manufacturing,
are subject to review by the EHS and maintenance and
product stewardship teams before contractor use such as
introduction, plus: site has conducted cleaning crews) plus:
sweeps to remove obsolete materials facility has a tollgate to
and chemicals, and is maintaining tight control introduction of new
control over the use of chemicals on chemicals, which are
site subject to review by the
EHS and product
stewardship teams before
introduction
Site(s) maintains a
complete inventory of its
raw materials and
chemicals used on site,
and has MSDS sheets for
all chemicals (including
any in process and
manufacturing,
maintenance and
contractor use such as
cleaning crews)

Evidence provided shows that a
certified or governmental third party
conducted a waste management audit
within the last 2 years, and that a
process to track and close findings is in
place
Evidence provided shows
that a certified or
governmental third party
conducted a waste
management audit within
the last 3 years, and that a
process to track and close
findings is in place
Site reports that it has
performed a third party
waste managment audit
in the last 3 years, but
unable to provide
comprehensive reports
and closure documents
Site has named a responsible person,
and can produce evidence of the
process and services that person(s)
use to update all the regulatory
requirements applicable to the site and
its operations, including off-site
transport
Site has named a
responsible person, but
does not have a systemic
process to ensure new
and modified regulations
and permits are reviewed
on a regular basis

Site has copies of all its permits up to
date, and a comprehensive filing
system with all permits, associated
documents and summaries of all
compliance conditions
Site has a list of all
permits plus backup
documentation, but the
permits are not up to date
or are incomplete

Site has copies of all its required EHS Site has an organized
permits, and a comprehensive file system to maintain
containing all associated regulatory permits, but has not
correspondence with authorities maintained all associated
regulatory
correspondence with
authorities
All wastewater and air emissions
sources have been captured on a site
map with sources identifed, process
and instrumentation diagrams that
indicated sources or matrix tables with
sources identified by column number,
etc, and field verification indicates that
all sources have been accounted for
and included in the documentation
Site has some of its
wastewater and air
emissions sources
captured through
documentation like site
maps with sources
identified, process and
instrumentation diagrams
that indicate sources or
matrix tables with sources
identified by building
column number, etc.--but
field verification shows
that not all the sources
have been captured
 Score 2 Score 0

Person has been Nobody identified as

assigned, but no special responsible
training

Site reports it has an No Management of

informal process for Change (MOC)
changes to be reviewed by process
EHS

Site reports that it has No evidence that an

conducted an internal audit audit of any kind
within the last 2 years was conducted
(1) Compliant labor and The site does not
employment policies have have a dedicated
been developed and (2) a human resource
labor management expert and/or wage
specialist has the basic and hour
required ability/knowledge compliance plan.
of wage and hour
requirements

Person has been Nobody identified as

assigned, but no special responsible
training

Facility has reviewed its Facility has not

procedures, identified its adopted a systemic
high risk processes and approach to
has begun to provide evaluating and
protective measures to managing health
employees and safety risks
Facility has used some Facility has not
mechanisms to communicated
communicate risks (based facility risks to the
on a representative employees
sampling of the
employees, some (10-
50%) of the employees
sampled are
knowledgeable about the
risks)

Site reports that it has No evidence that an

conducted an internal H&S audit of any kind
audit within the last 2 years was conducted

Site reports that it has No evidence that an

conducted an external industrial hygiene or
assessment within the last occupational health
2 years and there is some assessment has
evidence of protective been conducted
measures, but site cannot
provide documentation

Site has a rudimentary Site cannot show

system for tracking finding documentation that
closure, but unable to findings are closed
confirm that it is systemic

No evidence of a
training plan and/or
no evidence that
employees were
trained
Facility reports it has a
process that updates
employee training after
changes are made, but
unable to provide
documentation of training
The facility has a response
plan that only addresses
very basic potential
emergencies (fire) that
may occur on site. The
employees are not fully
aware of their
responsibilities during
potential occurances.
No evidence that the
facility has a
documented
process that
updates employee
training after
process changes
No evidence that
the facility has
developed a written
program to address
emergency
preparedness. No
drill are conducted,
Employees are
unaware of what to
do in the event of
an emergency.
Person has been Nobody identified as
assigned, but no special responsible
training

Some (10-50%) security No security

procedures are in place procedures
but are missing one or
more sections listed in
guidenotes

Employees are trained No evidence that

based on job description, security awareness
but records are not kept training is given
and refresher training is
not provided

Some evidence of No evidence that

expectations for reporting business has a
suspicious activities is process for reporting
found, but no formal suspicious activities
process is in place or supply chain
security breaches
At least 2 of the illustrative No evidence that
measures are in place controls are in place
to prevent the
introduction of
unmanifested items
into shipments of
goods to GE

Site reports that it has No evidence that an

conducted an internal or
third party audit within the
last 2 years, but unable to
provide copy of report and
closure documentation
audit/risk
assessment of any
kind was conducted

Supplier/site tracks energy No evidence of

use and costs can be energy costs tracked
verified nor usage
information being
logged; no reduction
plan

Supplier/site tracks water No evidence of

use and the site's costs
can be verified
water costs tracked
nor usage
information being
logged; no reduction
plan
Site(s) maintains a partial
inventory of its raw
materials and chemicals
used on site (including any
in process and
manufacturing,
maintenance and
contractor use such as
cleaning crews), and has
MSDS sheets for some
chemicals
Site reports an internal
audit was performed of its
waste management
process is but unable to
provide evidence
Although it was
observed that
chemicals are used,
site(s) has no
evidence that an
inventory or MSDS
sheets exists of any
of its chemicals and
raw materials used
on site (including
any in process and
manufacturing,
maintenance and
contractor use such
as cleaning crews)
No Waste
Management
process in place
Site has no
documentation
naming a person
responsible for
tracking regulatory
developments, and
updates that may
impact EHS
compliance at the
site

Site reports it has

permits, but cannot
provide a list or
inventory of them or
their requirements

Site does not have

an organized file
containing permits
and all associated
correspondence with
authorities
No evidence that
site has identified
and documented all
its wastewater and
air emissions
sources