In 2011, we initiated steps to establish a formal Environmental Management System, which we refer to as our Environmental Management Program (EMP). The EMP is designed to provide the basic framework for the company to responsibly manage environmental obligations applicable to its operations. The EMP is founded on the principles of ISO 14001 and United State Environmental Protection Agency (USEPA) compliance-focused environmental management system guidance. The EMP approach is designed to reduce environmental risk due to non-compliance, and provide a systemic method for continuous improvement.
The EMP documents how we identify environmental obligations, assess risk, monitor and track new and emerging requirements, and build compliance programs. In 2012, we will continue to build out elements of the EMP including the plan to have a collaboration site as a way to connect people with the content of the EMP.
Under the EMP, we will systematically review compliance obligations across all business units. The intent is to leverage existing processes to develop compliance programs that are scalable and sustainable across the enterprise. One example of a program enhanced in 2011 is our Hazardous Waste Management Program.
Federal and state environmental regulations require the responsible management of non-saleable consumer products. Some of these products when disposed of are considered hazardous waste requiring proper disposal. In 2011, we enhanced our Hazardous Waste Management Program in multiple ways to better manage this environmental obligation. We leveraged existing processes and technology to integrate the program into daily operations. For instance, store colleagues routinely use a radio frequency (RF) unit to process consumer products. The software to this hand-held device was upgraded to include logic that ensures proper disposition of consumer products that are considered hazardous waste when no longer useable for their intended purpose. The RF Unit provides simple, easy-to-implement steps that help assure a sustainable process for managing disposal of unwanted consumer products at our retail locations.
In addition, we have revised training received by colleagues in our retail stores. Training is now based on level of responsibility in handling hazardous wastes. This training ranges from basic awareness level training for new store colleagues to specialized training for photo lab and pharmacy colleagues.
Throughout 2012 we will continue to engage business units in the review of operation-specific regulatory requirements as we manage our environmental obligations and protect the environment.
Agency Notifications
Consistent with regulatory release reporting requirements under CERCLA, we reported the release of hazardous substances to the appropriate regulatory authorities. This reporting requirement was triggered by catastrophic water damage due to Hurricane Irene sustained at a CVS/pharmacy in Margaretville, NY. Emergency response contractors were brought in to provide clean up services. Because the building was so severely damaged, it was subsequently demolished. A report of clean-up activities was submitted as required.
