Corporate Environmental Management - Chapter 5 ppt

27 Chapter 5 Internal Survey The internal survey involves evaluating the two distinct missions that most company environmental managements face—namely, providing support for: 1. The corporate headquarters’ environmental activities, and 2. The company’s plant and operating environmental support needs. While interrelated, the two missions have distinct and separate challenges. Corporate headquarters support activity is a staff function by nature whereas supporting plant/operational needs, if it is to be successful, must involve some level of field operational buy-in to achieve effective integration. Corporate Headquarters The corporate headquarters mission involves coordination of the com- pany’s strategic environmental decisions. Activities such as tracking environmental legislation, evaluating potential economic impacts, and coordination with lobbying efforts naturally fall within this realm. Like- wise, the establishment of corporate environmental goals and coordinat- ing and maintaining the corporation’s key permitting and regulatory compliance framework falls within the realm of a corporate environmental staff mission. However, the hard realities of implementation at the plant/operations level bring up a series of questions and differences in environmental management philosophies. How much control does the corporate environmental management need over plant environmental support personnel? As shown in Exhibit 15, in some instances tight operational control over plant environmental activi- ties may be warranted when serious environmental issues are a necessary part of operational activity or environmental restraints have significant impact on plant production capabilities. In other cases, a corporate environmental staff may function in a “bully pulpit” fashion—setting the framework for compliance (e.g., SOPs, permits) or providing some level of internal audit but leaving day-to-day implementation responsibilities to the operational management. There is no one correct approach. Selection of an environmental management style depends on company culture, indus- try specifics, and organizational strengths and weaknesses. 55461_C005.fm Page 27 Friday, March 30, 2007 7:26 AM © 2008 by Taylor & Francis Group, LLC 28 CORPORATE ENVIRONMENTAL MANAGEMENT Using the four assessment categories and their 14-key criteria for success (presented previously) as the framework for the internal survey, the environmental management assessment team engages in: • Discussion and review of environmental policies and procedures; • Review of environmental records; • Plant walk-throughs; • Discussions with environmental personnel; and • Discussions with corporate and line personnel. The internal survey does not necessarily need to be an audit per se. In fact, there is a strong argument for keeping it oriented more toward breadth than depth, as shown in Exhibit 16. However, the survey should bore deeply on a selective statistical basis and focus on areas of particular concern to the board of directors. Exhibit 15. Positioning the environmental management role. Exhibit 16. Internal survey, examples of breadth versus depth. Complex Environmental Mission Bully Pulpit Driving Dad Friendly Uncle Encouraging Dad Straightfoward E nvironmental Mission Minimal Financial Risk Significant Financial Ris k ⇐ Corporate Line ⇒ Major issue management of regulatory negotiation Internal integration ⇓ ⇓ Plant walk-throughs e internal survey of environmental management should emphasize breadth with selected depth as dictated by management/board/public concerns. 55461_C005.fm Page 28 Friday, March 30, 2007 7:26 AM © 2008 by Taylor & Francis Group, LLC 29 Internal Survey Operations Elements of an effective risk management program at the plant level include evidence of an ongoing risk characterization and reduction pro- gram; episodic risk management systems reviews that include plant operating personnel; evidence of process (operational) safety standards and their implementation; evidence that EHS standards are being applied uniformly across facilities and (if applicable) being applied worldwide; evidence of a proactive emergency response, community communications, and involvement program; a product stewardship culture in place; and evidence of effective change management. The area for effective environmental change management is broad and goes beyond pipes, pumps, control systems, and information systems. For example, it can include changes in information systems such as integrated software systems covering all business activity, including EHS data. It is critical to ensure that information management systems are developed that readily flag unacceptable EHS risks to concerned management. There should be clear evidence that environmental risk management at the operations level is being driven by responsible management with the support of full-time EHS staffing experts. The said EHS subject matter experts should be tied operationally into project activities. At the very least, there should be a full-compliance philosophy with well-kept logs of potential concerns for tracking and resolution. It should be clear that the work process owner (plant operations management) is responsible for mitigating risks. Environmental risk miti- gation plans should be in place prior to considering system change and supported by a cascaded endorsement process including EHS senior management approval of acceptable risks. 55461_C005.fm Page 29 Friday, March 30, 2007 7:26 AM © 2008 by Taylor & Francis Group, LLC . differences in environmental management philosophies. How much control does the corporate environmental management need over plant environmental support personnel? As shown in Exhibit 15, in some. management. There is no one correct approach. Selection of an environmental management style depends on company culture, indus- try specifics, and organizational strengths and weaknesses. 55 461_C0 05. fm. Chapter 5 Internal Survey The internal survey involves evaluating the two distinct missions that most company environmental managements face—namely, providing support for: 1. The corporate