Environmental Resources Management (ERM) conducted an evaluation of DuPont's SHE Audit Programs directed by the Corporate Safety, Health and Environment (SHE) Excellence Center and implemented by the Company's four Global Regions.  ERM evaluated the elements and performance of the Programs in order to render an independent opinion about their effectiveness in achieving improved SHE performance throughout the Company.  The assessment was conducted between May 2006 and January 2007 and included a review of Program documentation, interviews with Program Managers and staff, selected interviews of site representatives who have been subject to the audits and observation of six audits.

The Programs were evaluated against three sets of criteria: external expectations set by organizations with standing in the SHE audit community (e.g., U.S. EPA, ISO, The Auditing Roundtable), DuPont’s internal SHE auditing standard, and generally accepted audit practices in comparable companies.  ERM reviewed the scope and elements of the Programs, the procedures utilized, the resources applied to implement the Programs and the degree and quality of management commitment.  Based on the information made available to ERM by DuPont, ERM has concluded that DuPont's Programs are generally consistent with, and in some cases, exceed expectations of the established criteria.  In our opinion, the Programs provide competent, reliable and objective information to management about the status of the Company's SHE compliance programs and performance.  Further, DuPont's management is responsive in correcting deficiencies when they are identified by the Programs.

As shown in Table 1, two of the Programs' elements, the written audit procedures and quality assurance, are quite advanced when compared to practices in other companies.  Of particular note is the publication, distribution and maintenance of (1) a formal Auditing Standard (S2Y) covering all SHE competencies, updated in October 2005, (2) formal, codified SHE performance standards for all sites, and (3) a global audit scheduling and tracking database.  These are all available worldwide on DuPont’s Intranet.  Moreover, the year 2006 was the first time in the eleven years of the annual evaluation that all elements achieved at least a “fully meets” score.  Notwithstanding this achievement, there are aspects of the programs and audits that could be improved.  Further discussion of these can be found in the body of the report.  Management has been informed of these areas in need of improvement and is taking steps to address them.  It should be noted that an eleven year-trend analysis indicates that solid, sustainable performance has been achieved in the past six years.