Posts filed under ‘Compliance Excellence’
Transparency Begins with Data Management
Connie Prostko-Bell
Meeting the demands of new product regulations requires better data management solutions. We sat down this week with 3E Company’s Connie Prostko-Bell to learn more about this emerging issue and to find out what companies are doing to provide greater supply chain transparency.
GT: Why do companies collect MSDSs and other product data from their suppliers? What is this information used for?
CPB: Operational risk and compliance management is increasingly focused on environmental issues across the supply chain. As companies strive to deliver sustainable ongoing improvements in compliance and risk management, they are closely scrutinizing the management of products in the enterprise, especially chemicals and other hazardous materials, with a special emphasis on fulfilling requirements in environmental, health and safety (EHS) regulatory compliance. A comprehensive view of compliance performance and risk management throughout the supply chain and product life cycle is necessary to promote and sustain ongoing improvement.
This vision is fueled by accurate and comprehensive content, including environmental, health and safety (EHS) product data, such as Material Safety Data Sheets (MSDS), which can be leveraged to ensure that the products that are incorporated into finished goods meet legal, regulatory, industry and self-imposed standards. Leveraging this type of data helps communicate to a company’s stakeholders that externally sourced processes and materials do not introduce legal, financial, ethical or market access risks to the company. Furthermore, it gives organizations an opportunity to advance their own value-based agendas by leveraging buying power to enforce desired practices.
GT: What trends are driving the management of supplier-sourced product data?
CPB: Manufacturers with complex supply chains are struggling under the burden of spiraling global EHS regulations. More often than not, they possess neither the requisite internal methodologies nor the necessary personnel to collect, analyze, share, and distribute key information related to supplier compliance and corporate risk across the various functional groups within the organization. Compliance issues such as GHS, REACh, RoHS and Frank-Dodd are driving the need for a common source of product data.
The shifting regulatory landscape also burdens suppliers, who often need help gaining access from suppliers and understanding the global EHS laws with which they must comply. Companies are increasingly recognizing supplier compliance as a critical component of business continuity efforts.
GT: A company’s efforts are only as strong as the quality of its data. How can companies ensure data quality, especially when they are dealing with a multitude of suppliers?
CPB: The number of suppliers can vary wildly from company to company. Generally speaking, it is safe to say that the larger the organization, the more suppliers it will have. Many factors influence this number such as geographical diversity of operations and customers, the complexity of the product line, and availability of the required raw materials. It is certainly not uncommon for a large company to have tens of thousands of suppliers. However, regardless of whether the company has hundreds or thousands of suppliers, managing supplier data can be a very challenging task. Finding, maintaining and acting on data is difficult and painstakingly time-consuming.
It is important that companies use documented, best practice methodologies and direct relationships to gather, refine and maintain data.
When it comes to sharing the information, you should choose an easy-to-use and practical system that meet each customer’s specific needs. The data should be broad, dynamically updated, and of the highest quality and accuracy. Substance- level regulatory data and product level MSDS data should be integrated together to provide a view into the impact of regulatory changes across inventories in the enterprise.
At the product level, from its inception to the present day, the vendor supplied product MSDS has evolved into a document that goes far beyond its original purpose, now serving as a source, foundation and clearinghouse for a range of safety and regulatory compliance data, including classification, transportation, environmental, ecological and disposal considerations. MSDS product-level data should be continuously updated with information and search technologies, documented best practice methodologies and through direct data obtainment relationships with raw material and other chemical product manufacturers.
Connie Prostko-Bell is a Senior Solutions Manager with 3E Company. She has 16 years of EH&S and chemical industry experience, spanning the project management, product safety and product stewardship sectors. She will share strategies for getting accurate supplier data during NAEM’s webinar on the topic Feb. 16.
Meet the NAEM Board of Directors: What are the EHS and sustainability trends to watch in 2012?
As part of NAEM’s 2012 Member Appreciation Week celebration, we sat down with members of the NAEM Board of Directors to talk about the EHS and sustainability trends to watch in 2012. Featuring Michael Miller of Dean Foods; David Newman; Mark Hause of DuPont; and Verne Shortel of NRG Energy.
Dow Chemical Co.’s Strategy for Addressing Product Stewardship Issues
With the growth in product stewardship regulations in Europe and beyond, chemical makers are facing unprecedented demand for transparency. In this video at our recent EHS Compliance Excellence Conference, Connie Deford, Director of U.S. Chemical Management Policy for Dow Chemical Co., discusses the impact these regulations are having and how the company is addressing them.
NRG Energy’s strategies for enterprise compliance
Tony Shea
At NRG Energy, environmental compliance is a management commitment. Through the pillars of its environmental management program, the Princeton, N.J.-based company delivers on this commitment in the approximately 42 power plants it owns and operates throughout the United States. This week, we caught up with Senior Manager of Environmental Business Tony Shea to discuss the company’s successful compliance strategies.
GT: When it comes to building a successful environmental management program, where do you begin?
TS: It starts with commitment from the very top of the company that environmental compliance is an absolute must. For NRG, that commitment is reflected in our environmental statement and our core values, and we do not make compliance decisions based on economics or other circumstances. It is understood that our plants simply must comply. And that commitment is constantly reaffirmed by our top management down through the plant management.
GT: Once the management commitment is in place, how do you embed compliance into the day-to-day operations?
TS: When we’re talking about power-generating facilities, compliance is a factor in many decisions operators make while on the job. At NRG we try to keep potential environmental impacts at the forefront of everyone’s thinking as we perform our daily decisions and actions.
In 2007, we implemented a system to track environmental compliance performance called the Environmental Key Performance Indicator (EKPI), which tracks incidents such as permit violations, notices of violation, reportable spills and even administrative compliance. The EKPI also accounts for each location’s participation in our econrg initiative, which includes projects focusing on environmental stewardship, greenhouse gas reduction, or water conservation projects in our local communities.
At the beginning of each year, every facility gets a target score. To reach the maximum EKPI score, the facilities need to have a perfect compliance record, and that score is ultimately tied into the bonus of every employee at the plant. Over the past four years I think it has really changed the mindset to reinforce the message that environmental compliance is everyone’s job.
Training is also a critical component of compliance. We’ve improved operator training, enabling them to better understand environmental requirements and potential impacts as they make decisions in their day-to-day operations.
GT: What are the other elements of your program?
TS: In addition to our EKPI, our environmental management information system (EMIS) and our audit program also help us ensure compliance.
We initially implemented our EMIS across all of our generating facilities in early January 2007. That initial roll-out included using it for our EKPI and for tracking environmental events. Shortly thereafter, we began using the EMIS to track any environmental responsibilities that come from permits or environmental regulation. If it’s something that can be scheduled, we’ve scheduled it into that system. The system then sends an email to the employee responsible for making sure it gets done. We’ve seen significant improvement over the years in administrative compliance thanks to our task tracking system.
Every significant facility also gets audited annually by an independent, third-party consulting firm. One unique aspect of our EKPI is that audit findings do not count negatively. We want to find all potential issues and correct them. Audit findings only impact a facility’s EKPI score if the corrective actions are not completed in a timely manner, or if there are repeat findings from year to year. We believe this sends the right message to the employees and encourages a collaborative relationship between the auditors and plants. We want perfect compliance, so it is important to identify potential risks or weaknesses and address them immediately. Our senior management and our plant management are on board with that and welcome the audits.
Tony Shea will share more details about NRG’s compliance program at NAEM’s EHS Compliance Excellence Conference on July 27-28 in Minneapolis.
Let’s talk about metrics
Carol Singer Neuvelt
After an exciting week in San Antonio talking about environmental, health and safety (EHS) management information systems (MIS), I’ve been thinking a lot about what an impressive feat data collection and management really is. All I can say is ‘Bravo.’
Perhaps nothing drives home the enormity of this task more than hearing EHS managers describe the process for mapping work flows or hearing Mark Stoler recall how he managed to get General Electric’s approximately 300,000 employees to adopt a single, global EHS tracking system.
Without this kind of peek under the hood, it might seem as though comprehensive data like this is easy to come by. It isn’t.
Beyond the initial challenge of figuring out how to document internal processes, though, identifying and reporting metrics is often just as laden with obstacles. While most of the information is intended to enhance internal decision-making or track performance, there is, of course, a growing interest in a company’s EHS and sustainability metrics by outside entities as well.
And when it comes to external requests for data, the burden of responding usually falls on the EHS function. In our recent ‘Green Metrics that Matter’ survey of the NAEM Board of Regents, 74 percent of those who responded said the corporate EHS manager took the lead role in external reporting. For 17 percent of respondents, these requests took up as much as one-quarter of an employee’s time (and we expect these numbers to jump as we survey our full membership).
With the amount of time EHS folks are spending, it’s not surprising that about half of respondents said they were fairly dissatisfied with the current state of EHS/environmental, social, governance (ESG) disclosure.
There must be a better way.
In the latest installment of SustainAbility’s ‘Rate the Raters’ research, the firm identified the following steps ratings firms should take to improve their influence and make the process easier for corporate leaders:
- Improve transparency: Transparency leads to trust, according to the researchers. “We find that the stronger ratings in our selection are the most transparent. When raters provide strong disclosure of their methodologies and results, they give companies clear blueprints for improving performance in the future…This also gives clients, ratings users and other stakeholders a sound basis on which to decide whether to use rating information when making decisions (which drives ratings adoption or uptake).”
- Start engaging stakeholders: It’s time for ratings firms to do the same kind of stakeholder engagement that sustainability-oriented companies now do, the study found. “The majority of ratings today are based on arms-length assessments of performance,” the report stated. “Going forward, we believe that every rater can and should spend more time with the companies they assess, and that there are myriad benefits to doing so (e.g. gain stronger understanding of their businesses, verify publicly-reported information, help companies understand ratings and improve sustainability performance).”
As a step toward improving the reporting process, NAEM will host a collaborative dialogue on May 4 for EHS and sustainability decision-makers, as well as representatives from research firms, investor relations departments and NGO’s. The purpose is to help attendees better understand one another’s objectives and concerns, which we hope will help improve the consistency, clarity and value of corporate sustainability efforts.
As we put together the program for the day, what are the kinds of issues would you like us to address? What questions do you have for ESG research and ratings firms?
Do-it-yourself EHS MIS: An interview with InterGen’s Mark Chrisos
In 2008 InterGen launched a proprietary, internally built system to track its environmental, health and safety (EHS) performance. We spoke with Mark Chrisos, Director of Health, Safety, Security and Environment, to learn more about the benefits and challenges of doing it yourself.
The Green Tie: Why did you decide to build your own system?
We originally had a system that was an off-the-shelf system and it became very cumbersome and labor intensive. We took the best attributes and decided to take a home-grown approach.
The Green Tie: What do you like about your new proprietary system?
One of the things we didn’t have with our old system was the ability to instantaneously enter data. To address that, the IT designers developed an incident reporting system that allows the site user to enter an event right away. (We own power plants across the world so when something happens, we all want to know about it quickly.) That event is then instantaneously sent to a selected group of people within our company through our internal e-mail system, with a timeframe based on the severity of the incident.
In the health and safety area, for example, a lost time incident needs to be entered within that shift, but whereas an unsafe act or condition could be entered by the end of the week. So we try to prioritize incidents and act on them based on that priority. It also allows us to make a comment back or an email back to check in and find out what’s going on. So it really makes our job easier on the incident side.
The Green Tie: Before you created your ‘BITS’ system, InterGen used multiple tracking systems. What are some of the benefits associated with streamlining your efforts?
The operations team, the maintenance team and the HSE teams work very closely together, so the new system allows us to enter incidents related to equipment, health and safety environment and even now, security. The plant teams can use this one system to add an event, to search an event, to look at monthly data, to look at reports, all in one screen.
Often times if there’s an equipment failure, it might have health safety or environmental implications. If you have a machine that uses oil and that machine fails, for example, you might have a spill around the equipment. With this system, you can track that both ways. All this then rolls up in a monthly report that we can generate based on location or by the fleet for everything going on in the company.
The Green Tie: Has the system changed your safety culture? If so, how?
I think the culture is changing based on the fact that people are now very comfortable reporting all incidents. For the past several years, we have emphasized that we need to collect data to track it because the more data we have, the better off we’ll be.
The new system encourages reporting system and makes it easier for us to trend data. People love to report things now but they expect us to report back to them with the results. So we provide feedback via trending on a quarterly basis and we develop programs, procedures and processes based on the trends that we see.
We can now track incidents by body parts, for example. If we see a bunch of eye injuries, we’ll be able to investigate that issue and look at whether our safety glasses program is working. And all the coordinators on the site-level appreciate it that we’re looking at it from a corporate or fleet approach and offering recommendations on how to address these issues.
The Green Tie: What were some of the challenges of putting a system like this together?
The first thing is internal cost. After that, it’s a matter of getting employees focused, making it a priority, and keeping up with it. And we found that if you don’t keep up with it, it’s not going to work. Every year, we do a survey of users to ask them what else they’d like us to track. We then issue an update once a year.
Teaching employees how to use it is another consideration. We’ve learned that if you don’t do the proper level of training, people are not going to use it. So we have a full-time IT/training coordinator and we work together on each year’s release. We have video conferencing with everybody; and we have a test site they can try out before it goes live. All these things are important to get people comfortable with it.
The Green Tie: If you could do it again, what are some of the things you would do differently?
What I think we learned is if you spend more time in the design phase it will save you time with the updates. We have far fewer changes this year than last year, but I think it’s important take a lot of time to chart out the plan. Getting more people involved also could have helped make the process smoother. Often times people who are unfamiliar with the issue can help catch things you overlook.
To learn more about InterGen’s internally built system or to discuss the latest trends in management information systems (MIS), join NAEM in San Antonio March 2 and 3 for the 2011 EHS MIS Conference.
Tracking EHS MIS: An interview with Margery Moore
Margery Moore
Since 2001, NAEM has been tracking the evolution of the EHS MIS marketplace through a bi-annual benchmarking survey of users. This week we caught up with Margery Moore, Director of EHS Strategic Alliances at BNA, to discuss the 2011 survey and her perspective on the category today.
The Green Tie: What is an environmental management information system (EMIS) and how does it help improve EHS and sustainability performance?
An environmental management information system, or EMIS, is part of a billion-dollar-industry that, at its heart, is focused on compliance.
Increasingly, the data companies have has been traditionally managed (i.e. air, waste, water types of pollution impacts) is becoming a hot commodity within the context of climate or sustainability management. As such, tracking and managing carbon and greenhouse gases (GHG) is becoming more commonplace. This is reflected in the new types of modules and features available in EMIS. This growth area is also reflected in brand new software companies popping up to handle just GHG and carbon.
Does the use of a software tool make a company sustainable? No. But it does allow a company to better manage and analyze their data, and hopefully, make better decisions.
The Green Tie: You’ve been working on this survey since 2001. What changes have you seen over time?
The market has definitely grown, then contracted in the early 2000′s as larger companies bought smaller software companies to gain access to new features or customers.
More recently, we’ve seen a small explosion of sustainability and climate/carbon tracking software. Time will tell, however, what sticks.
The Green Tie: New on the survey this year is a question about social media. Why is this important?
The use of social media tools is having an impact, as environment, health and safety (EHS) professionals start to blog and use Twitter. A few years ago, that was unheard of! The public now demands transparency, and they expect their employers and companies in general to provide that.
Social media is also empowering the average consumer in incredible ways. You can use your phone and download an app, scan a product code, and Good Guide will tell you its eco-rating! Pretty cool. That is just one example.
The Green Tie: What are you most interested in learning from this year’s survey?
How social media is impacting companies, and the hot new features software providers are now offering. It also will be very interesting to see if budgeting for EMISs has changed over the past two years. 2008-9 were terrible years for spending. Have we recovered? Big question.
The Green Tie: Do you think people are surprised by how much others spend on EMIS?
Yes, frankly. Those outside the industry are shocked when I tell them it’s a more than billion-dollar-a-year industry! But, when you explain that each company probably has hundreds of environmental, health and safety regulations to comply with, each with its own data requirements to prove compliance, it’s clear that software is the only way to go. Can you imagine trying to do this in Excel or on paper? It would be a nightmare.
To benchmark your software system against your peers, take the 2011 EHS MIS benchmarking survey. Respondents will receive a copy of the results. To learn more about the latest ways to improve your EHS performance through data management, join NAEM in San Antonio on March 2 and 3 for the 2011 EHS MIS conference.
It’s never been easy being green
Stephen Evanoff
Conventional wisdom laments that today’s political atmosphere has become so polarized that the nation isn’t able to establish consensus-based national policy on contemporary environmental and conservation issues like we did in the good old days when both major political parties and the public saw eye-to-eye.
My recent reading of Timothy Egan’s, “The Big Burn – Teddy Roosevelt and the Fire That Saved America” reminded me that it has never been easy being green.
Egan, a Seattle-based, Pulitzer Prize-winning author, outdoorsman, and columnist for the New York Times, tells the story of the August 1910 wildfire that consumed an area the size of Connecticut. The fire swept through parts of Montana, Idaho, Washington and British Columbia in a matter of days, wiping out entire towns, and killing more than a hundred people.
Woven into the narrative of the events around the fire is the story of how President Theodore Roosevelt and Forest Service Chief Gifford Pinchot were able to establish vast national forests. As they put it, these forests should be for the use and enjoyment of all the people, rather than for exploitation by wealthy individuals and corporations, which had been the case until then. Most of us take the concept of the National Forests for granted. Yet Egan explains how radical the concept was at the time, and points out that there were many powerful forces aligned against Roosevelt and Pinchot.
It makes the reader wonder, how on earth Roosevelt and Pinchot did it. But, Egan shows us that Roosevelt and Pinchot had powerful forces of their own: their vision of what was best for the long-term, well-being of the nation, their energy and personal commitment, and their trust in the American people. The battle of conservation of our National Forests versus consumption by private industry continued throughout the twentieth century. As the twenty-first century emerged, conservation had ultimately prevailed due to reasons both economic and ideological.
I found the story inspiring and relevant to today’s environmental challenges, be they global, national, or organizational. When applied wisely, the combination of a clear and unselfish vision, hard work, and belief in the decency and wisdom of others can overcome significant resistance.
We’ve all fought uphill battles, albeit not on the epic scale of Roosevelt and Pinchot. I’d like to hear your inspiring stories. How have you overcome resistance within your organization to proposed EHS policies? How have you persuaded entrenched interests to support EHS initiatives with long-term benefit to your organization?
Understanding Renewable Energy Certificates
Steve McDougal
Renewable energy certificates are a vital tool for offsetting a company’s carbon footprint, but there is still plenty of confusion about how best to use them.We caught up with Steve McDougal, Executive Vice President of Marketing and Business Development for 3Degrees Inc., and asked him to shed some light on the subject.
GT: What is a renewable energy certificate (REC)?
SM: A REC is proof or verification that one megawatt-hour of renewable energy has been created and delivered to the grid. Power is traded like a commodity, undifferentiated from fuel sources, and a REC is like a claim check that corresponds to electricity generated from renewable resources. It’s purchased separately, however, so the buyer of that REC knows that they’re funding (or helping to fund) the same amount of renewable energy going into the grid as what they pull out of the grid.
GT: Who uses RECs?
SM: RECs are used by a variety of organizations. They’re used by utilities to meet state government renewable energy compliance regulations; they’re used by organizations on a voluntary basis to meet sustainability goals and by green building professionals to earn Green Power Credit points towards LEED green building certification.
GT: What kind of premium could a buyer expect to pay for energy from a renewable source?
SM: For a voluntary buyer purchasing a REC that is sourced from anywhere in the United States, the premium is about 1 percent.
GT: How do RECs help companies reach their sustainability goals?
SM: While businesses may do their best to reduce their electricity usage, at the end of the day, all organizations still need electricity to operate. Unfortunately, there is a significant environmental impact associated with the electricity that they use. The purchase of RECs mitigates this impact, while helping improve the profitability and return on investment of renewable energy projects, thereby driving more of those projects forward.
GT: When should a company use a REC versus a carbon offset?
SM: If you want to “green” your electricity, RECs are the way to go. But they are not meant to be used as a carbon offset for Scope 1 or Scope 3 greenhouse gas emissions, primarily because RECs are not a precise way to measure greenhouse gas emission reductions. They’re a proof of one megawatt-hour of clean electricity, but they are not designed to balance out the greenhouse gas emissions or mitigate the environmental impact of energy use other than electricity. Everything else outside of electricity use, from driving your car to burning some natural gas to putting another log on the fire, that’s what you want to use carbon offsets for.
GT: How do you demonstrate value/metrics for those who buy these credits?
SM: The U.S. Environmental Protection Agency’s calculator provides one look at the environmental impact RECs can have. You can enter the amount of megawatt-hours that you’re buying and it will convert it to a measure that shows the amount of greenhouse gases that would have been generated using traditional electricity generation. It then tells you how these greenhouse gas emissions correspond to the amount of greenhouse gases produced annually by an average car, or absorbed by an acre of forest in a year. Many companies also measure themselves by setting a percentage goal and increasing the amount of RECs they use over time.
GT: Can REC’s totally offset a company’s carbon footprint?
SM: One should always look at RECs as a complement to energy efficiency and conservation efforts, realizing that it’s not one or the other. The best approach is to say, ‘We’re going to reduce our energy use, costs and environmental impact as much as possible,’ using energy efficient technologies and conservation. But even if we do our best, we will still use some electricity from the grid, which will have an environmental impact. And a comprehensive environmental sustainability effort can mitigate this impact by supporting the generation of the same amount electricity from renewable energy sources as the electricity you use from the grid.
Steve McDougal is Executive Vice President of Marketing and Business Development for 3Degrees Inc. and a member of NAEM’s Affiliates Council. You can hear him speak more about renewable energy credits during the upcoming webinar “Understanding the Business Value of Renewable Energy Certificates” Jan. 13 from 1:00-2:15 p.m.
Toward sustainability: Interface Inc.’s ‘Mission Zero’ journey
In 1994, Ray Anderson, founder of Interface, Inc., outlined an ambitious new vision for his company: to achieve sustainability by 2020. Lindsay Stoda, a Senior Business Analyst with the company, spoke at the recent EHS Management Forum about the metrics Interface uses to measure its sustainability progress. This week, we caught up with Lindsay to learn more about the company’s Mission Zero goals.
Lindsay Stoda
Q: Where did the Mission Zero goal come from?
LS: Sparked by questions from customers and the ideas he encountered in Paul Hawken’s book, “The Ecology of Commerce,” our founder Ray Anderson realized that business and industry were part of the larger system that was damaging the environment and that it was not going to be a sustainable future if business continued in that direction. And realizing that it was someone’s job to lead industry down that path, he decided to ask his company and his employees to be that leader.
Q: How do you measure success against your Mission Zero Goals?
LS: We’ve always followed the “What gets measured gets managed” philosophy, so our way of being able to track and ensure that we’re making progress is through four different measurement platforms:
- Eco Metrics: Measure environmental impact
- Socio Metrics: Measure social impacts
- Quest program: Measures waste elimination
- Ecosense: Measures the activities on a plant-level that contribute to our sustainability goals
Q: How did Mission Zero change the work of Interface’s EHS department?
LS: Prior to Ray’s epiphany, we had a more traditional manufacturing environment, health and safety (EHS) department focusing on safety and compliance. Today, it’s typically the same folks because the tracking of that kind of information all kind of overlaps with the sustainability roles, except that people’s EHS roles developed a sustainability-minded focus.
Q: Can you tell me about some of your efforts toward creating closed loop products?
LS: We have a strong push to create closed loop products using recycled and bio-based raw materials. This process basically involves returning the materials in used finished product back to raw materials.
For carpet tile, there are two main components: There’s the face fiber and the fluff — the surface that you walk on — and then there’s the backing, which is different from residential carpet in that it’s a vinyl backing and it’s heavier, to hold the tiles to the floor and give them dimensional stability.
We had previously been able to cut the fibers off the front, take the backing, crumble it up, melt it down and return it to backing. But now we’re able to take the nylon fibers from the face of the products, shave them off and return them to our fiber suppliers to create new face fiber with post consumer recycled content.
We bring back both our carpet as well as competitors’ products through ‘ReEntry’—our recycling program. We collect used product back from the marketplace, run it through our process, and return backing to backing and fiber to fiber. Since the program began, we have diverted more than 100,000 tons of material from landfills.
Q: One of the goals you’ve identified is providing Environmental Product Declarations (EPDs) for all of your InterfaceFLOR products by 2012. What does that entail?
LS: We have used life cycle assessment (LCA) for several years now as we’ve tried to evaluate different materials and processes for manufacturing our products. The Environmental Product Declaration is a 10-15 page summary of the life cycle assessment results, everything from global warming potential to toxicity to resource use throughout the entire life cycle of the product. There is a lot of different environmental information out there and we thought the most useful thing for our customers would just be to give them the facts they need to make the decisions about what type of products they’d like to purchase. So it’s really the good and the bad. It’s just the facts. We collect the data and have it third-party verified to ensure it is complete and accurate.
You can hear Lindsay talk more about using metrics during “Defining the Metrics that Matter,” part of NAEM’s Best of the 2010 Forum webinar series, on Tuesday, Nov. 16. To register, visit www.naem.org.
