Compliance and Remediation
The foundation of Bristol-Myers Squibb’s EHS program is to be in compliance with government regulations and worldwide corporate directives designed to help protect the environment, our workers and the public. We continue to show improvement in compliance, although there were times when we failed to fully meet permit or regulatory requirements.
Bristol-Myers Squibb cooperates with local, national, and international regulatory bodies to help develop environmental standards. In many countries, our facilities are recognized as being leaders in EHS performance, and government authorities look to our EHS experts for best practices in EHS management.
Violations and Fines
Bristol-Myers Squibb tracks EHS citations, administrative orders and similar notifications worldwide as a result of government interactions and inspections. Whenever a facility violates a regulatory requirement, management determines the cause of the noncompliance, takes appropriate corrective measures, and, if necessary, develops an action plan to prevent its recurrence.
There were about 210, 230 and 130 government-initiated interactions in 2006, 2007 and 2008 respectively (including, but not limited to, site visits or inspections) at Bristol-Myers Squibb facilities relating to EHS. In 2008 there were about 40 safety and 90 environmental related government interactions. A number of sites were sold or closed in 2008, and there were fewer inspections.
The global reporting information provided below reflects only penalties associated with government inspections and does not include, for example, self-reported permit exceedances or minor administrative errors. Also, fines associated with a violation are assigned to the year the fine was paid.
Recent Citations History
The number of regulatory citations issued to Bristol-Myers Squibb was 21, 8 and 18 in the years 2006, 2007 and 2008, respectively. In 2008, eight citations were safety related and ten were environmental. The total penalties paid by the company with the corresponding number of citations in parenthesis were less than $20,000 (6) in 2006; zero dollars in 2007; and $55,000 (2) in 2008.
Reportable Spills
All Bristol-Myers Squibb facilities maintain a spill prevention and response plan to minimize and properly manage any spill or unintended release to the environment. Our long-term goal is to prevent all spills.
Investigation/Remediation Activities
Bristol-Myers Squibb, like most major industrial companies, is involved in a number of environmental cleanups associated with past activities, even though the activities were lawful and acceptable at the time they occurred. We invest resources to achieve cleanup in a manner that is environmentally and financially responsible. We utilize risk management techniques whenever possible to determine the most effective approaches to pursue at each cleanup site. Our prevention-based initiatives, such as product life cycle reviews and best practices transfer, will minimize our future involvement in remediation activities.
Bristol-Myers Squibb’s EHS and legal staff routinely interact with government agencies, and we often pursue cleanups using innovative remedial technologies. We also work very closely with other Potentially Responsible Parties to partner with government agencies and community groups toward the common goal of providing cost-effective remediation that protects human health and the environment.
Through the end of 2008, Bristol-Myers Squibb estimates its share of the total future costs for these sites is approximately $61.8 million. In 2008, the company paid approximately $6.6 million (excluding legal fees) for investigation and remediation of such matters, including liabilities under CERCLA, state and other regulatory authorities. The company had paid approximately $7 million last year and less than $6 million (excluding legal fees) in each of the prior five years before that.
Investigation/remediation projects are ongoing at the following Bristol-Myers Squibb operating facilities in 2009:
- Delicias, Mexico
- Humacao, Puerto Rico
- New Brunswick, New Jersey
- São Paulo, Brazil
- Swords, Ireland