DUE DILIGENCE PROTOCOL

REQUEST FOR PRE-AUDIT INFORMATION

Name of Legal Owner:

Address of Legal Owner:

Ownership Status of the Facility and Number of Years at the Facility:

Permit/Generator Status of Facility:

Address of Main Facility (if different) and number of years at the facility:

Permit/Generator Status of Main Facility:

Location(s) of all other company owned/operated facilities and number of years at each facility:

Permit/Generator Status of all other company owned/operated facilities:

Please describe the scope of services you provide, service capabilities and response limitations relative to:

Transporting to a TSDF (authorized facility)

Use of owned or leased storage or transfer facilities

Use of contractor TSDF’s (Toxic Service Disposal Facility)

Describe your labor/management relations.

• Have you had any strikes in the last 5 years?

• Is there a chance of a strike?

• What is the potential of a work stoppage occurring during the proposed agreement period with [COMPANYNAME]?

• How would this impact your stated capability or capacity?

• Have you any alternate plans in place to minimize impact?

• Average number of units processed per week or per year.

DOCUMENTS WE WISH TO SEE SUBMITTED:

A List of 3 to 5 Customer References (please include any healthcare references):

Name:

Address:

Phone #:

VENDOR CLIENT BASE/COMMUNITY RELATIONS:

Please tell us the percentage of revenues a [COMPANYNAME] contract would represent:

• What is the percentage of revenues generated from Fortune 500 companies?

• What percentage of revenues would be generated from [COMPANYNAME]?

Please submit a listing of your major (or top 10) customers.

Company Name:

Address:

Contact:

Phone:

OPERATIONS AND CONTROLS:

Please provide us with a general description of your operations.

• How long have you been at your site(s) and what was it before (prior operations)?

• Describe site size(s), zoning restrictions, fleet size, radius of operations, etc.

• Please describe the criteria you use to select for subcontracted fleets.

• Please describe the processes at your site, including all waste streams you handle.

• Please also describe the regulated processes and the Federal/State licensed waste streams.

DOCUMENTS WE WOULD LIKE TO SEE SUBMITTED:

1. Site process descriptions and flow diagrams, for both owned and leased facilities, where [COMPANYNAME] waste streams are processed or commingled.

2. Data on site structures, including aboveground and underground storage tanks. Provide data on contents, tank number and volume, age, materials of construction, containment, etc.

3. Copies of an index of written standard operating procedures (SOP’s) for each of your process and operational activities, contingencies, preventive maintenance that are of potential impact to [COMPANYNAME] (e.g., metals separation activities, cleaning operations, etc.).

4. Copies of agendas, or objectives and outlines of, personnel training programs and personnel certifications as applicable – to include but not be limited to Driver Safety, HAZWOPER, Hazard Communication, and Hazardous Waste training procedures.

5. Copies of environmental, safety or health; compliance or liability audits of your fleet management program (for owned and/or subcontracted fleets).

6. Copies of environmental, safety or health; compliance or liability audits of owned or leased storage, transfer and recycling facilities, and owned or leased disposal sites.

7. Copies of indemnity contract provisions provided by any of your contractors.

8. Copies of most current permits for all EH&S-related elements (e .g., RCRA Part A/Part B, Storage/Transfer, air, water, UST/AST, etc.) or status of permit applications.

INSURANCE AND FINANCIAL:

Please respond to the following questions about your company’s insurance coverage by completing the following table (we will also be asking for similar information on subcontractors, in the Subcontractor’s section):

Insurance:	Yes/No:	Carrier:	Coverage:
Comprehensive General Liability
Workers Compensation
Automobile:
Pollution Liability
Other

Please Provide your Dun & Bradstreet (D&B) Number:

Parent Organization:

Facility:

DOCUMENTS WE WOULD LIKE TO SEE SUBMITTED:

1. Copies of certificates of the above-named insurance coverage’s.

2. Please submit copies of the past three years of 10K’s, Annual Reports, and audited financials.

3. Please attach a copy of the latest D & B report.

VENDOR COMPLIANCE HISTORY:

Are you, or have you been in the past five years, involved in any removal, remediation, or other environmental clean up actions? (Yes / No) If yes, please identify the location of the action and the nature of your activities at or with the site.

Are you, or have you been in the past five years, involved in any lawsuit relating to the work you perform? (Yes / No) If yes, describe the nature of the lawsuits and, if settled, the outcome.

Are you, or have you been in the past five years, involved in any lawsuit or government agency enforcement action relating to the environmental contamination of real property? If yes, describe the nature of the enforcement action or lawsuits and, if settled, the outcome.

In the last five years, have you been cited for violations of any federal, state, or local environment laws or regulations (including, but not limited to, any laws or regulations relating to waste management or disposal, waste water, or air emissions)? (Yes / No) If yes, identify the agency issuing the citation, the nature of the violation(s), corrective action taken and current status.

In the last five years has your company been cited for violations of the federal Occupational Safety and Health Act (OSHA) or an equivalent state law? (Yes / No) If yes, indicate the nature of the citations and provide copies of any serious, willful, or repeat citations. Also provide a narrative of corrective action taken, and the current status of citations.

In the last five years has your company been cited for violations of any federal, state, or local hazardous materials transportation laws or regulations? (Yes / No) If yes, indicate the nature of the citations and provide copies of any serious, willful, or repeat citations. Also provide narrative corrective action taken, and the current status of citations.

Are any environmental agency, OSHA, or transportation agency investigations or citations currently pending or on appeal? (Yes / No) If yes, please describe the nature of the investigation or appealed violations?

VENDOR SUBCONTRACTOR RELATIONSHIPS:

Do you subcontract for any of the services that would be provided to [COMPANYNAME]? (e.g., waste disposal, waste reclamation, transport, transfer stations, TSDF, spill response) (Yes / No) If so, identify your subcontractors (including any alliances or partnerships into which you would enter to handle any capacity contingencies), frequency of use, and circumstances under which they would be used.

Subcontractors:

Company:

Service:

Alliance / Partner:

Frequency:

What due diligence, if any, have you done on your subcontractors? Please describe in detail and provide any supporting documentation. If none has been done, please explain why.

Subcontractor:

Due Diligence performed:

Are any of your subcontractors involved in any current or past (5 years) lawsuits relating to the work it performs? (Yes / No) If yes, describe the nature of the lawsuits and, if settled, the outcome.

Subcontractor:

History of Current, or Past, WORK RELATED Law Suits:

Are any of your subcontractors involved in any current or past (5 years) lawsuits or government agency enforcement actions relating to the environmental contamination of real property? (Yes / No) If yes, describe the nature of the enforcement action or lawsuits and, if settled, the outcome.

Subcontractor:

Current or Past CONTAMINATION Law Suits:

In the last five years, has your subcontractor been cited for violations of any federal, state, or local environmental laws or regulations (including, but not limited to, any laws or regulations relating to waste management or disposal, waste water, or air emissions)? (Yes / No) If yes, identify the agency issuing the citation and the nature of the violation(s)?

Subcontractor:

Current or Past ENVIRONMENTAL Law Violations:

In the last five years has your subcontractor been cited for violations of the federal Occupational Safety and Health Act (OSHA) or an equivalent state law? (Yes / No) If yes, indicate the nature of the citations and provide copies of any serious, willful, or repeat citations.

Subcontractor:

Current or Past OSHA Law Violations:

In the last five years has your subcontractor been cited for violations of any federal, state, or local hazardous materials transportation laws or regulations? (Yes / No) If yes, indicate the nature of the citations and provide copies of any serious, willful, or repeat citations.

Subcontractor:

Past or Current HazMat Law Violations:

Are any environmental agency, OSHA, or transportation agency investigations or citations involving your subcontractor currently pending or on appeal? (Yes / No) If yes, please describe the nature of the investigation or appealed violations?

Subcontractor:

Past or Current OSHA Transportation Law Violations:

Please indicate which of the following insurance policies your subcontractor carries, the name(s) of the carrier, and the amount of the coverage (you may need to provide this for each of your subcontractors):

Insurance:	Yes/No:	Carrier:	Coverage:
Comprehensive General Liability
Workers Compensation
Automobile:
Pollution Liability
Other

DOCUMENTS WE WISH TO REVIEW ON THE SITE:

1. Samples of hazardous waste manifests or Bills of Lading for the past three years.

2. Samples of hazardous waste analytical reports for the past three years.

3. Waste disposition and reconciliation records for the past three years.

4. Onsite QA/QC program.

5. Wastewater monitoring protocol; and selected logs for discharges from all owned facilities for the past three years, which [COMPANYNAME] waste streams may impact.

6. Discharge and monitoring reports which require submission, or access to agencies at the site.

7. Spill and contingency plans.

8. Copies of spill records for review for the past three years.

9. Copies of agency inspection or investigation reports for the past three years.

10. Facility closure plan.

11. Copies of employee training records for all referenced training programs, for the past three years.

12. Regulatory (Local, State and Federal) agency citations or Notices of Violation/Findings for the past five years.