Implementing a Strong Environmental Management Program

AuthorFrank B. Friedman
Pages213-260
Chapter 5:
Implementing a Strong
Environmental Management
Program
In addition to management commitment, good staffing, and a workable
organizational structure, corporations need to put into place a strong en-
vironmental program. The basic objectives of a good program are listed in
Figure 5-1.
Figure 5-1
Objectives of a Strong Environmental
Management Program
213
• Strong management commitment to and involvement in a company’s
EHS management programs, and accountability for non-compliance
with laws, regulations, and corporate policies is strictly enforced;
• Designing the organizational structure, whether centralized or decen-
tralized, for effective program implementation, including appropriate
policies, directives, and other action-assurance mechanisms;
• Developing a consistent and transparent process, which is an important
element of maintaining reputation and reputation turnaround strategies;
• Integrating the environmental function with the safety and risk engi-
neering (process risk) functions;
• Committing EHS staffs to maintaining a high level of professional ex-
pertise encompassing a range of essential disciplines and backgrounds;
• Seamlessly integrating the EHS management system with company
general management system;
• Regular, timely, and uniform reporting from the operating line
through senior management to the board of directors;
• Prompt identification and resolution of environmental issues;
• Establishment of preventive programs and procedures; and
• Identification of developing issues or trends.
To meet these objectives, a program should have the elements listed in
Figure 5-2.
Figure 5-2
Elements of a Strong Environmental Management Program
Strong corporate environmental policies and directives/
procedures;
A high-quality reporting system, including a computerized, central-
ized information system (whether in a centralized or a decentralized
management system);
An internal planning document and timetable;
A capital expenditure review system;
A legislative and regulatory action program;
Training and education programs; and
A facility assessment program.1
This chapter discusses in detail each of these elements, except for the facility
assessment program. Because facility assessments are so critical to environ-
mental management, they are discussed at length in the following chapter.
In these cost-conscious times, it has been my experience that successful
programs well integrated in the company’s businesses can save a corporation
substantial sums, while keeping both corporate and divisional staff size to a
minimum. As discussed in the previous chapter, keeping staff to an absolute
minimum is essential. To do so, it is necessary to review job functions and
program needs continually,consolidating functions and eliminating unneces-
sary positions. In addition, development of broad-based directives/proce-
dures and guidelines that can be monitored on an exception basis, rather than
on day-to-day performance, allows corporate personnel to concentrate more
effectively on long-range planning, program development, and compliance.
A computerized database and the general use of computer-based techniques
allow for effective and efficient use of data, facilitate understanding of issues,
and free the staff to concentrate on broader issues.
Having an effective EMS will also avoid having a compliance-oriented
system mandated by EPAor the DOJ as part of a settlement in an enforce-
ment action. My experience in this area is that these government-imposed
systems do not achieve the kind of integration and cost effectiveness that is
the value of EMSs in the business context, despite the professed goal of the
Compliance-Focused Environmental Management System (CFEMS)2“to
integrate into a facility’s daily operations an EMS that results in the com-
pany achieving and maintaining compliance over time….” “Once the EMS
214 Practical Guide to Environmental Management
is developed, EPAs role is to ensure that the EMS is implemented according
to the terms of the settlement agreement.”3
In a survey taken of industry representatives involved with such man-
dated EMSs4it was found that it was difficult to determine “whether the
EMS requirements correlate with an increase in environmental perfor-
mance,”5although “[m]ost industry representatives credited the EMS with
increased monitoring, recordkeeping, and reporting of environmental is-
sues. Improvements in compliance with environmental laws and regula-
tions were specifically noted.” “All industry representatives reported that
their respective EMS resulted in increased self discovery of environmental
problems as well as increased awareness of environmental issues.” It was
also felt that “more incentives are needed to encourage EMS generally.”6
Environmental Policies and Corporate Responsibility
In setting the stage for implementation of environmental programs, it is im-
perative to establish the company philosophy by promulgating an environ-
mental policy.
Once corporate policy is set, it must then be translated into direc-
tives/procedures and guidelines for implementation. At the corporate level,
as discussed subsequently, I prefer the use of the term “directive” rather
than “procedure” to describe more general governance requirements, as op-
posed to more specific corporate procedures designed to provide opera-
tional guidance or facility-specific procedures designed by a division or the
facility itself for a specific facility. Most companies use the term “proce-
dures” for both. The Occidental corporate group has developed specific re-
quirements for divisional environmental organizations throughout the cor-
poration. Policies, directives/procedures, and guidelines each perform dif-
ferent functions and it is important to keep the three concepts separate.
Policies should be broad-based, outlining the key aspects of an environ-
mental program and establishing the company’s commitment to that pro-
gram. Means of implementing policies should be described separately in
procedures and guidelines. Directives/procedures should be mandatory
methods of implementing policies. Guidelines should be written when im-
plementation of a policy does not lend itself to specific procedures or when
a procedure itself needs additional explanation.
Generally, I prefer directives/procedures to guidelines because proce-
dures are tighter. As a company’sprogram matures, it may be practical and
preferable to substitute procedures for guidelines. Occidental and Ato have
replaced almost all of their guidelines with directives/procedures. For ex-
ample, while Occidental has a procedure for review of property acquisitions
and sales, the specific areas to consider vary with the scope of the transac-
Implementing a Strong Environmental Management Program 215

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