Operations

Operational Compliance

ETRACS

All Clorox facilities follow a customized environmental management and compliance program.

At Clorox, we’re proud of our environmental management record. Our top tier environmental management system, called Environmental Tracking, Reporting and Compliance System (ETRACS), enables us to track, report and ensure environmental compliance of our facilities. Site-specific compliance activities driven by this system include all federal, state, and local permitting requirements. Sustainability activities such as GHG reporting and water usage are also tracked in this system.

ETRACS, which is a very robust notification based system, provides weekly and monthly reminders and deadlines for environmental compliance tasks and activities that need to be completed. It also works as an effective tool to facilitate compliance task planning for our environmental coordinators and provides important regulatory compliance deadline information to our Site Managers. Ultimately, an Environmental Coordinator at each of our sites works to ensure that all compliance tasks are completed to meet regulatory requirements.

Clorox is also inspected regularly by regulatory agencies that focus on health, safety and environmental compliance for all Clorox product lines at all our manufacturing facilities. These regulators include Federal, State and Local governmental agencies. In our Fiscal Year 2009 (July 1, 2008 through June 30, 2009) dozens of health, safety and environmental inspections were completed by these agencies across Clorox’s North American facilities. Nearly 70% of these regulatory visits were environmental in nature. ETRACS, employee training and thorough recordkeeping ensure that our facilities consistently meet the regulatory requirements and help ensure the human and environmental safety of our on-site employees and surrounding communities.

GHG Inventory Process

While the Clorox GHG inventory has not been independently verified by a third party, our GHG inventory gathering process and calculations (for 2005 – 2010) are all led and conducted by an independent third party environmental services firm with detailed knowledge of the operations and air emissions characteristics of the major Clorox manufacturing facilities. This firm compiles and utilizes source data (electricity, natural gas, fuels and chemicals) provided by Clorox facility personnel to calculate associated emissions using global industry standard and commonly accepted methodologies. The firm also reviews the data submitted by Clorox plant personnel and verifies it independently before computing the associated GHG emissions.

With respect to accuracy, completeness and methodological soundness, it is noted that many of Clorox’s U.S. facilities are subject to federal and state environmental regulatory programs that require the annual preparation and responsible official certification of emission statements that utilize much of the same data that that is used to compile the GHG emission inventories reported in this website.

GHG Verification

In 2011, we conducted a partial verification of our GHG emissions (Scope 1 and Scope 2 emissions associated with the use of Natural Gas at our U.S. facilities and all utility based electricity purchased at our U.S. facilities). The Natural gas consumption and electricity purchased at our U.S. facilities accounts for close to 60% of our overall global GHG emissions. This verification was conducted by a recognized firm that conducts independent third party GHG verification.