Dean Foods operates more than 80 manufacturing facilities and more than 300 distribution locations across the U.S. Many of these locations must comply with hundreds of specific regulations. We strive to conduct business in compliance with all applicable federal, state, and local regulations to ensure the protection of the environment and safety of our employees. Our Audit Committee provides oversight of our ethics and compliance activities.
Code of Ethics
Becoming a more responsible company requires responsible actions by our employees. We strive to treat all employees with dignity and respect, and we provide expectations of conduct for all employees. Our Code of Ethics establishes many of the standards which we expect our directors, officers, and employees to follow to build value for our stakeholders. We also provide an anonymous Code of Ethics Help Line for all employees: 1-888-332-3980. Review the Dean Foods Code of Ethics for more information.
Environmental Health & Safety Management
In addition to employee safety, we focus on improvements in our environmental compliance and safety management performance. We comply with all applicable regulations from the U.S. Environmental Protection Agency, Occupational Safety and Health Administration, and state and local agencies. We use a computer-based third-party auditing system tailored to the dairy industry to conduct robust audits at our facilities. In 2011, we conducted 55 environmental audits in our facilities, and we conduct 25-30 safety audits every year. We also began tracking resolution of all audit findings and created a performance measurement for speed and verification of closure. We continually train our environmental health and safety professionals – stationed at each manufacturing location and several of our distribution locations – to ensure compliance and a high level of environmental performance.
Regulators perform hundreds of inspections each year at our facilities, and we track citations and fines from these visits. In 2010 and 2011, our environmental citations led to less than $50,000 in fines related to environmental compliance for both years. In 2010, we paid $136,838 in fines related to safety citations from OSHA or state safety agencies. In 2011, due to increased focus by OSHA under a National Emphasis Program (NEP) focused on Process Safety Management (PSM), we experienced an increase in fines related to citations totaling $268,679. A majority of the 2011 citations were related to a single facility inspection linked to the OSHA NEP. In response, we have increased our attention around PSM to ensure our compliance at all of our locations.
Additionally, we participate in industry associations like the National Association of EHS Management (NAEM) and International Institute for Ammonia Refrigeration (IIAR) to conduct benchmarking and develop industry standards and best practices to improve environmental performance not only for Dean Foods but for the food and beverage industry in general.
Our private fleet is subject to the rules and regulations established by the Department of Transportation's Federal Motor Carrier Safety Administration as well as the laws of multiple state, county and local governments. Compliance with regulations covering hours of service, driver qualifications, drug and alcohol testing, vehicle readiness and safety are all part of our daily activities. Our employee drivers and management team take pride in maintaining an outstanding safety and compliance record, and we provide safe driving training to all our drivers. Learn more about our Transportation and Distribution efforts.
During 2011, we were subject to more than 1,300 roadside inspections by law enforcement personnel as reported to the Department of Transportation (DOT). These inspections concluded with 67 percent having no violations and 96 percent of the inspected drivers/vehicles immediately returned to service. During the 24 months of 2010 and 2011, we were involved in 57 DOT Recordable Crashes resulting in injuries and/or fatalities with an equivalent vehicle involvement rate of 0.14, compared to the national rate of 0.22*. Each of the behavior analysis and safety improvement categories under the Motor Carrier Safety Measurement System were well below intervention thresholds.
*2010 Large-Truck Involvement in Fatal and Injury Crashes and Involvement Rates, 2001-2010 as published in the U.S. Department of Transportation National Highway Traffic Safety Administration Traffic Safety Facts 2010 Data "DOT HS 811 628 Large Trucks" dated June 2012. NHTSA's National Center for Statistics and Analysis, Washington, D.C.