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Our Management Awareness and Action Review System (MAARS) is the assessment process through which we identify and mitigate environment, health, and safety (EHS) risks. This process enables our Family of Companies to proactively address EHS issues and ensure compliance with regulatory requirements and our standards. Our Worldwide EHS unit tracks performance at every site through immediate collection (within 72 hours) of incident reports and periodic joint assessments with site management.
Although the events we are experiencing continue to be minor, the number of non-compliances has been trending upward, from 20 in 2008 to 57 in 2010. Most of these were related to waste handling or air and wastewater permit non-conformances, and all were corrected promptly.
To address this trend, we are reinforcing our compliance training, strengthening oversight of the audit process, and putting greater emphasis on the importance of comprehensive and ongoing self-assessments as part of the MAARS program.