In our quest to achieve zero accidents, we have implemented a continuous improvement program of development, planning, doing, checking and review. The Management System involves fifteen elements, working together to create a successful HSQE Program. The fifteen elements all participate in a coninuous improvement program, made up of the following parts:

Policy Development – create an environmental policy and make it public. Implicit in this first step is a commitment to continuous improvement, to the prevention of pollution and, at a minimum, compliance with all environmental regulations.

Planning – set objectives and targets for improving environmental performance. This is done by first analyzing the environmental impacts of Gradient Resources operations, creating a plan and then prioritizing highest impact areas for improvement.

Doing – create a structure, as managed by the HSQE Director, which becomes a mechanism for training and communicating EMS policy to all stakeholders (Gradient employees, contractors and subcontractors). This includes providing a clear understanding of the impacts their jobs have on the environment and then helping them implement EMS procedures and goals in their various worksites and facilities through clearly written policies, procedures and records, and development of procedures for any emergencies that may occur: spills, emissions, accidents and such.

Checking – continuous measurement of how successfully we are achieving our environmental objectives. Auditors will routinely check the EMS to ensure that procedures are being followed and goals met. Reports will be discussed with the appropriate managers and employees with the goal of correcting problems and continually improving operations. This process also recognizes good performance and anticipates problems before they occur.

Management Review - a formal annual review of the EMS by the Gradient Resources Leadership Team and Safety Committee. This process depends on managers asking key questions: Are we meeting our objectives and targets? Are we saving money? What changes seem necessary to help the EMS function at a higher level? They may decide that changes to the EMS need to be made and act to make improvements. These questions bring the entire process back again to the planning phase, and the cycle begins anew.