Corporate Environmental Management - Chapter 5 ppt

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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.

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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.

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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.

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