Organization and Staffing for Environmental Management

• Author: Frank B. Friedman
• Pages: 181-212

Chapter 4:

Organization and Staffing for

Environmental Management

People are the key to success of any environmental management pro-

gram. A crisis—either within a company or in a similar com-

pany—may galvanize people to initiate or improve an environmental man-

agement program. Occidental, Ato, Allied Chemical Corporation, and Un-

ion Carbide Corporation each suffered traumatic experiences that raised

awareness and inspired efforts to avoid future problems. Many others are

rapidly changing and their management programs may also change to re-

flect their product mixes, philosophies, and management changes. The les-

sons learned, however, are still valid. Such crises catch management atten-

tion, increase understanding of potential problems, lead to development of

strong programs, and increase support and funding for program implemen-

tation. A crisis also fosters greater cooperation, which may not always exist

in corporations that have not had such experiences. Under any circum-

stances, however, management commitment, a good organizational struc-

ture, and appropriate staffing serve as the foundation of a strong environ-

mental management program.

Environmental management (Occidental and Ato) programs develop in

different ways. The discussions in this chapter draw heavily on examples

from the companies where I have had responsibility for environmental

management, as well as more recent experiences as a consultant. The expe-

riences of these companies in developing broad-based programs to deal ef-

fectively with past problems, to avoid future problems, and to do both cost

effectively with small staffs may be useful to others. I discuss them in detail

to provide concrete examples of how the elements of an environmental

management program can be implemented in specific situations. I also uti-

lize my experiences as a consultant.

Since 1957, Occidental expanded primarily through domestic acquisi-

tions in a wide variety of areas, together with rapid growth in the interna-

tional oil and gas area and limited growth in domestic oil and gas opera-

181

tions. Its headquarters-level efforts to develop corporate-wide environmen-

tal programs began in September 1978 with the appointment of a director of

health and environment. Divisional programs had in fact commenced long

before. Between September 1978 and May 1981, significant progress oc-

curred in developing and carrying out a range of environmental programs.

These programs included informal assessments, reporting on significant is-

sues and the status of permits, and limited identification of upcoming regu-

latory and legislative issues. Divisional staffing was upgraded to carry out

corporate requirements. Progress accelerated with additional staff and re-

sources. In May 1981, Occidental created a corporate environmental attor-

ney position. Between June and October 1981, the company expanded the

corporate staff to add a vice president, a records administrator,a manager of

assessments, and a manager of external affairs (subsequently director of ex-

ternal affairs and compliance). Senior management’s involvement contin-

ued and expanded. During 1980 and 1981, following a Securities and Ex-

change Commission (SEC) settlement and creation of the Board of Direc-

tors’ Environmental Committee,1the Board and top management gave the

corporate environmental department a mandate to develop and maintain

systems that would independently determine the status of compliance and

ensure that the company was properly addressing environmental concerns.

Today the Occidental staff is still small. In 1990, the Risk Engineering

Department (then consisting of four professionals and now composed of

two professionals with another professional in a divisional position) was

added to the group in recognition of the close relationship between person-

nel safety and loss prevention. Occidental’s environmental counsel was

then based in Washington, D.C. (although he subsequently transferred to

the chemical division in Dallas), along with two individuals handling legis-

lation and regulation—one of whom doubled as the Director of Environ-

mental Affairs. A manager of health, safety, and environmental programs

was added in Los Angeles late in 1992. Although the Environmental Com-

mittee had always concerned itself with safety and health, in 1989 its name

was changed to the Environmental, Health, and Safety (EHS) Committee to

emphasize these concerns. In addition, a third outside director was added to

the committee.

Ato was the U.S. chemical division of a large, but decentralized, French

oil and gas, chemical, and health company, Elf Aquitaine. Elf Aquitaine

was merged into another large French oil and gas, chemical, and health

company, TotalFina, in the first quarter of 2000. The name of the chemical

operation was then changed to Atofina. I refer generally to Ato rather than

Atofina or Arkema, since my personal experience was with Ato, although

the basic systems have not changed. Ato (now Arkema), which was the

product of a 1990 merger of Pennwalt, M&T Chemicals, and a few chemi-

182 Practical Guide to Environmental Management

cal plants of the U.S. subsidiary of Elf Atochem, S.A., always had an EHS

staff. Ato upgraded and expanded that staff in 1994 with the creation of my

former position, Senior Vice President and Executive Committee member

reporting directly to the President and Chief Executive Officer. As a mem-

ber of both the Executive Committee and the Manufacturing Committee, I

was involved in major management decisions, which helped ensure integra-

tion of our programs and sent a strong signal as to their importance. In addi-

tion, we significantly increased our staffing, particularly in environmental,

health, safety, and auditing. (Appendix E contains a sample organization

chart for a Vice President for Health, Environment, and Safety.) We also

added two of my senior staff to the Management Group, the next level of

management below the Executive Committee.

The following discussion outlines a variety of approaches to organization

and staffing for environmental management that Occidental—and

Ato—used to develop strong environmental management programs at min-

imal cost, together with the context in which these controls were—and are

being—developed. These approaches have also been tested in my consult-

ing practice in general manufacturing facilities, oil and gas exploration,

power and utilities, manufacturing, and construction companies, among

others. These approaches have several key characteristics, which are listed

in Figure 4-1.

Figure 4-1

Key Characteristics of Strong Environmental

Management Programs

• Top corporate management is strongly committed to and in-

volved in the company’senvironmental management programs.

• The organizational structure, whether centralized or decen-

tralized, is designed for effective program implementation.

• The environmental function is integrated with the safety and

risk engineering functions and integrated with the business.

• Turf problems among staff groups and divisions are mini-

mized, primarily by maintaining a thinly staffed organization

and focusing on the primary concern of getting a job accom-

plished. Decisionmaking is largely free from bureaucratic con-

straints.

• Both corporate and divisional staffs are committed to main-

taining a high level of professional expertise encompassing a

range of essential disciplines and backgrounds.

Organization and Staffing for Environmental Management 183