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Compliance Assurance Program
Our company has long recognized that compliance with all applicable environmental health and safety laws and regulations is a minimum requirement in assuring the success of our organization. All employees, from officers to frontline employees, are accountable for compliance.
Our Compliance Assurance Program establishes types of assessments, reporting results to management, corrective actions, tracking status of open items, confidentiality of information, record retention, and roles and responsibilities. In order to assure every effort is made to maintain compliance in our complex and diverse operations, the following four-tier process is established by the management practice.
Tier I — Ongoing Self-Assessments
The Tier I process is relatively informal and involves routine checks of EHS programs to ensure the program elements and standards are being accomplished. Each business unit or facility creates and maintains a plan describing how their Tier I process is implemented. Typical program elements include:
- Reviews of mandatory training progress reports
- Reviews of monthly trend reports
- Field observations and walk-downs
- EHS data review
- Review of company/industry event reports/lesson learned critiques and the use of the department’s performance indicators
Tier II — Focused Self-Assessments
Company EHS professionals conduct more formal and focused self-assessments annually in each business unit/department. Tier II assessments are structured, comprehensive reviews of program performance across the facility or department and/or the company. The Environmental Advisory Team and the Safety and Health Advisory teams develop the Tier II assessment plan at the beginning of each year.
Tier III — Audit Program
Cross-functional teams are used to conduct detailed annual compliance audits of EHS programs. The corporate EHS Audit Group is responsible for creating a schedule of audits at the beginning of each year and to facilitate the process so that each audit is completed. The Tier III process also includes an annual review of the Tier I plans and Tier II process to ensure they are being implemented according to the EHS Best Management Practice.
Tier IV — Periodic Compliance Reviews
Periodically, a detailed review of the compliance status of EHS programs are conducted. These reviews are used to establish the baseline of compliance within the EHS programs and identify areas for future Tier II assessments. The reviews are completed either by an independent third party, by internal teams of EHS professionals or by a combination of internal and external professionals. Such reviews may also be done at the direction of the Pinnacle West Law Department, utilizing an independent third party or an internal team of EHS professionals.
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