CSX Public Safety, Health, and Environmental Management System

CSX Public Safety, Health, and Environmental Management System As one of the nation s leading suppliers of rail and intermodal transportation, CSX Transportation (CSX) is committed to minimizing the impact of company operations on the environment and ensuring the safety and health of our employees and the public. We back our commitment with a variety of sound programs that promote public safety, health and environmental stewardship and sustainability. This commitment drives us to continually measure, track and improve Public Safety, Health & Environment (PSH&E) Department performance. CSX has developed a PSH&E Management System Standard (Management System) for the company that incorporates major elements of ISO 14001 and is consistent with the Responsible Care management system. The CSX Management System is tailored to CSX operations and provides the framework to assure regulatory compliance and minimize the impact of our operations to the environment, our employees and contractors, and the communities in which we operate. This approach aligns with the company s core values, ultimately helping CSX achieve the right results the right way. Approach Effective PSH&E management requires a cohesive vision and effective ground level implementation. Our corporate vision is put into practice every day through the CSX Environmental Policy (Policy) which has been endorsed by the company s chief executive officer. The Policy lays out a set of expectations that all employees at every level of the organization follow. It includes commitments to comply with applicable PSH&E related regulations, improve the company s environmental footprint through technology enhancements and pollution prevention, safely transport hazardous materials, ensure the safety of the public and local communities, protect and manage CSX land assets, actively engage with key CSX stakeholders, provide services that help customers reduce their environmental footprints, and continually improve our Management System and performance. CSX must assure compliance with all applicable PSH&E related laws and regulations. Compliance assurance involves the identification of relevant requirements, designation of actions to meet those requirements, and verification to ensure that those requirements are met. Requirements include laws, regulations, permit conditions, corporate policies and procedures, and related industry best management practices. The CSX Management System also reflects the company s commitment to sustainability and stakeholder engagement beyond what is required by law. Sustainability includes focus areas such as energy reduction, fuel efficiency, pollution prevention, water conservation, waste reduction, environmental remediation, biodiversity protection, and climate management. Stakeholder engagement includes the communication of potential hazards to key stakeholders and the development of plans and techniques to respond to PSH&E incidents. Providing stakeholders with a communication vehicle to relay PSH&E related concerns or potential hazards to CSX is another aspect of stakeholder engagement. The CSX Management System focuses on performance. CSX s impact on the environment, the public, and its employees depends on how CSX personnel execute responsibility in the field and in CSX 1

facilities. Clear and direct statements of PSH&E policies and programs help guide those actions, but it is the employees of CSX and their actions that make the difference. The PSH&E Management System The CSX Management System establishes a consistent set of programs, processes, and procedures for use across CSX operations. Key Management System components include identification of legal compliance requirements; environmental and hazardous materials aspects assessments; training; and defined roles and responsibilities. The Management System is made up of several different levels: At the highest level, the CSX Environmental Policy is a public statement of the company s commitments with respect to environmental performance and hazardous materials transportation and management. This policy is provided in Appendix A and is publicly available at www.csxcsr.com. Based on that commitment, the CSX Management System Standard frames the baseline expectations that CSX has set for itself with respect to PSH&E performance. It includes the principles of commitment, planning, implementation, verification and management review. CSX maintains this written summary of the Management System Standard that supports each of the 19 Management System elements. A copy of the PSH&E Management System Standard is provided in Appendix B. Implementation of the Management System Standard is accomplished primarily through the management of key programs and processes at the corporate and facility levels. For consistency, the programs and processes are organized around the tenets of compliance assurance. These programs and processes include the formal identification of legal and other requirements, evaluation of potential PSH&E risks of our operations, assignment of roles and responsibilities for meeting PSH&E requirements, training, and operational controls. Verification programs including internal inspections and independent compliance and management system reviews, have been developed to ensure that our PSH&E performance continually improves. CSX is continually striving to maintain its leadership position among railroads for PSH&E-related performance. For more information, please contact Skip Elliott, Vice President of the Public Safety, Health & Environment Department at skip_elliott@csx.com. 2

CSX PSH&E Management System Public Safety, Health & Environment (PSH&E) Policy 1.1.1: CSX Transportation (CSX) shall develop and implement a written policy that reflects its commitment to public safety, health, and the environment. 1.1.2: The policy and related commitments shall be communicated to CSX employees and be publicly available. Sustainability 1.2.1: CSX shall establish and maintain programs for preventing pollution, minimizing environmental impact, and enhancing sustainability in areas such as energy use, fuel efficiency, waste, water, environmental remediation, biodiversity, and other related media. Progress in these areas shall be tracked and reported to management. Planning Hazard Assessment 2.1.1: CSX shall maintain a process to identify and evaluate PSH&E hazards, risks, and impacts associated with its operations, activities, and processes. This information shall be annually reviewed and updated. Legal and Other Requirements 2.2.1: CSX shall establish and maintain a procedure to identify and communicate applicable PSH&E legal and other requirements to relevant personnel and vendors working for CSX or on CSX property. CSX shall also identify and communicate new and changing PSH&E legal, regulatory and other requirements to relevant personnel. Continual Improvement Goals 2.3.1: CSX shall establish annual PSH&E performance goals and measurements. The goal setting process shall consider company commitments, past and present performance, and desired future improvements. Responsibilities and time frames for achieving each goal shall be specified. 2.3.2: CSX shall track and report progress towards achieving its PSH&E goals. PSH&E Programs and Processes 2.4.1: CSX shall implement programs and processes to meet its PSH&E commitments; control PSH&E hazards, risks, and impacts; and meet regulatory requirements. PSH&E Programs and Processes 2.4.1: CSX shall implement programs and processes to meet its PSH&E commitments; control PSH&E hazards, risks, and impacts; and meet regulatory requirements. 2.4.2: Summary information shall be maintained for key PSH&E programs and processes. Summary information shall include an overview of the legal and other requirements that apply to the program or process, actions that are taken to meet those requirements, and verification activities that can be used to assure that actions are taken and requirements are met. 3

Implementation, Operation and Accountability Roles and Responsibilities 3.1.1: The PSH&E roles, responsibilities, and authorities of CSX personnel, contractors, and other vendors working on CSX property shall be defined, documented when appropriate, and communicated in order to ensure effective PSH&E management. Resources 3.2.1: CSX management shall provide sufficient financial, human, and technical resources to ensure effective PSH&E management. Training and Awareness 3.3.1: Personnel responsible for meeting and maintaining compliance with PSH&E requirements shall be competent on the basis of appropriate education, training, and experience. 3.3.2: PSH&E training needs shall be identified for each operating group and communicated to relevant personnel. 3.3.3: PSH&E training, including regulatory and PSH&E awareness training shall be provided to relevant personnel and documented. Communication 3.4.1: Procedures shall be established to ensure effective communication of relevant PSH&E hazards, risks, impacts, goals, improvement opportunities, and information to CSX personnel and other interested stakeholders. 3.4.2: Procedures shall be established for receiving, documenting, and responding to relevant communication from interested stakeholders. Stakeholder Engagement 3.5.1: CSX shall identify and facilitate engagement with key stakeholders such as communities, investors, customers, suppliers, regulators, and business partners who have expressed an interest or concern with CSX s PSH&E-related issues. CSX shall consider relevant stakeholder concerns when assessing hazards and risks, setting goals, and planning operations and activities. Documents and Records 3.6.1: CSX shall establish and maintain procedures for managing and controlling PSH&E documents and records. 3.6.2: A written description of the PSH&E management system shall be developed and maintained. The description shall explain each element of the PSH&E management system and provide direction to relevant supporting information. 4

Operational Control 3.7.1: CSX shall implement and maintain appropriate operational controls for its significant PSH&E hazards, risks, and impacts where engineering controls, operating procedures, or management processes are needed to mitigate risk, increase sustainability, uphold safety, ensure regulatory compliance, meet stakeholder expectations, or prevent other adverse PSH&E-related impacts. Emergency Preparedness and Response 3.8.1: CSX shall maintain procedures to identify potential accidents and emergencies and to prevent and mitigate the adverse PSH&E-related impacts that may be associated with them. 3.8.2: CSX shall periodically test its emergency preparedness and response procedures where practical. Verification Performance Measurement 4.1.1: Appropriate verification activities shall be established for key PSH&E processes to ensure that requirements are met, risks are managed, and performance is improved. Verification results shall be provided to appropriate management and incorporated into program improvements. 4.1.2: Key PSH&E performance metrics shall be identified, documented, tracked, and reported to management on a regular basis. Inspections and Assessments 4.2.1: CSX shall maintain internal procedures to verify compliance with regulatory and other requirements, ensure the functionality of operational controls, identify sustainability improvement opportunities, and review adherence to CSX procedures. 4.2.2: CSX shall periodically evaluate its operations, activities, and processes for compliance with applicable PSH&E legal requirements using independent assessors. Assessment results shall be provided to management and incorporated into program improvements. 4.2.3: CSX shall periodically evaluate its PSH&E management system to determine whether it has been properly designed, implemented and maintained. Assessment results shall be provided to management and incorporated into program improvements. Corrective Action 4.3.1: CSX shall establish procedures for identifying, documenting, investigating, tracking, and correcting identified PSH&E deficiencies and take appropriate action to prevent reoccurrence. Management Review 5.1.1: Management shall periodically review the PSH&E management system to ensure its continuing suitability, adequacy, and effectiveness. The review shall address the possible need for changes to PSH&E-related commitments, goals, objectives, and other elements of the PSH&E management system, including CSX s commitment to continual improvement. 5

CSX ENVIRONMENTAL POLICY CSX is committed to protecting the environment and the safety and health of the public, customers, and employees in all aspects of the company s operations. We strive to minimize impacts on the environment and the communities in which we operate. We work to maximize the business and its positive impacts by delivering the best service to our customers. The company s decisions and actions are guided by the following principles: Skilled and Committed Workforce Conduct operations safely. Leverage the CSX Environmental Management System to ensure compliance with environmental laws and regulations, internal policies and best management practices. Train and empower employees to fulfill environmental responsibilities. Communicate openly with employees, customers and the public regarding the company s environmental programs. Fuel Efficiency and Supply Chain Engagement Improve our environmental footprint by utilizing state-of-the art technology and pollution prevention efforts to reduce energy and fuel consumption and waste minimization through comprehensive recycling and reuse initiatives. Assist customers in reducing their transportation-related greenhouse gas emissions by promoting highway to rail conversions and continuously seeking to improve our locomotive fuel efficiency. Take environmental stewardship beyond CSX by encouraging suppliers to follow environmentally sustainable practices, engaging in public-private partnerships that promote environmental responsibility and fostering communications with communities and public agencies where we operate. Water Management and Conservation Recognize water availability concerns and manage our water consumption by identifying and implementing water reduction, recycling and reuse measures. Maintain the quality of our water discharges by applying good operating practices. Recognize and Respond Take immediate action to report and respond to situations that could negatively impact the environment, such as unauthorized dumping, releases or other accidents. Maintain broad business continuity plans and site-specific operating plans to maximize responsiveness to events that could include those resulting from extreme weather or shifting populations. Explore and Protect Explore, test and implement the use of alternative energy sources and energy efficiency opportunities. Protect local biodiversity and habitats while managing properties, constructing new facilities and managing remediation projects. Continue to improve environmental performance by setting and reviewing targets and goals that protect people and the environment using sound business practices. 6