Posts filed under ‘Risk Management’
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.
Signs of a Strong EHS Culture
Stephen Evanoff
At this year’s NAEM Forum in Tucson, several speakers and participants made the point that a strong environment, health and safety (EHS) culture is a prerequisite to achieving and sustaining a high-level of EHS performance, and EHS managers are better served by focusing on building an EHS culture than focusing strictly on outcomes. Building a culture that values EHS is difficult and takes years, so it’s important to have a clear vision of what a strong EHS culture looks like. Here are my thoughts on the core characteristics of a strong EHS culture.
- Top management is involved and visibly supportive: Senior managers include EHS in enterprise goals, metrics, and operations reviews. They engage in safety-related activities, such as safety walks and self-audits, and set a clear and consistent tone through their actions that EHS is a core value.
- All levels of management are accountable: EHS comprises a significant portion of performance evaluations for managers and supervisors. Managers and supervisors are expected to create a safe work environment for their associates, and ensure the people under their supervision tend to their EHS responsibilities with the same rigor as they do quality, productivity and schedule.
- EHS is integrated into core business processes: The EHS program is made operational through the enterprise business management system and standard operating procedures. In enterprises where EHS is well-integrated, EHS doesn’t require special attention or management exhortations. It is simply how business is done.
- EHS is communicated effectively and frequently: EHS requirements are understood by all associates. New associates receive EHS training appropriate to their jobs as part of orientation. Management realizes that the importance of EHS must constantly be reinforced to achieve and maintain a high-level of performance.
- Doing the right thing is innate: Associates have a high-level of EHS awareness, receive sufficient and continuous EHS training and are given the tools to ensure effective EHS management. Associates do the right thing and do things right, even when nobody is watching.
- Associates are motivated: People find intrinsic value in high EHS performance. They understand its contribution to the success of the enterprise and take pride in doing their part.
What characteristics do you think are essential for a strong EHS culture?
Sustaining a Safe Workplace through Design
Walt Rostykus
As safety practitioners, we know that engineering controls (elimination, isolation or substitution) are the first and preferred levels in the Hierarchy of Controls. By eliminating or reducing the exposure to a hazard through the design of a job or workstation, we establish a level of safety for all people working there. Engineering controls, also called Prevention through Design (PtD), also reduce the need for administrative (behavioral) controls and use of personal protective equipment. PtD is not a new concept, but is a recent initiative that is taking hold again.
The National Institute for Occupational Safety and Health (NIOSH) is leading a national initiative to promote this concept and highlight its importance in all business decisions. The concept continues to focus on planning and design of new workstations and process through two steps:
- Identifying hazards and
- Designing out the hazards through engineering controls.
It sounds easy. But if it is, why do environment, health and safety (EHS) programs struggle to control hazards after the fact? Why do safety professionals and management still rely heavily on behavioral and administrative controls instead of engineering controls? In my experience and through Humantech benchmarking studies, we’ve identified the three key elements for successful PtD processes as “At the right time, by the people (in the right role), and with the right criteria.”
- Right time: Prevention starts at the design phase when layout and tool design are concepts. This is where chemical, musculoskeletal disorders (MSD), and pinch-point hazards (to name a few) are easily identified by reviewing drawings and mock-ups. Changes made during the design phase to add capture ventilation, reduce reach distances, and add guarding cost 1/10 to 1/100 of what they would cost if made retroactively.
- Right people (role): The person(s) who designs the workplace or tool or specifies equipment is the best person to find and fix unacceptable exposures. Typically, these people are in an engineering role (process, production, mechanical, facilities or new product design engineers). Benchmarking studies continue to show that a common characteristic of companies with effective ergonomic improvement processes is that engineers, not solely the safety staff, are responsible and accountable for low-hazard design of the workplace.
- Right criteria: For engineers to be successful in designing jobs and workstations with low risk/hazard, they need the right tools. I am not referring to a shelf of engineering textbooks, but a limited and focused set of design guidelines, specific to that product or industry, that quickly provides the acceptable limits for design. Examples of ergonomic design guidelines include standing workstation height; reach distance; force limits for reaching, pulling or pressing; and viewing distance and placement. From this, engineers can quickly design the physical parameters of the workplace to fit the capability of the working population.
The concept of PtD sounds simple. And, in fact, it is simple. As simple as patching a leaky boat so you can paddle, not bail. Is PtD working in your organization? Is it practiced at all levels of the organization, or does EHS have to be the cheerleader and driver of the process? If success relies on EHS, what are the barriers you’ve encountered and how have you overcome them?
Leveraging EHS/S Expertise for Non-financial Risk Management
Charles Redinger
Organizational risk management has evolved from a singular focus on financial risk, to a broader perspective that includes enterprise-wide and non-financial risks. Approaches such as enterprise risk management, strategic risk management, value risk management, etc. are morphing into an area called non-financial risk management (NFRM). A paradox in this arena is that even though risk management is important, it is fragmented, siloed and poorly integrated in companies. NFRM frameworks are weak or non-existent.
A solution to this paradox can be found right down hall in the EHS/S (environmental, health, safety and sustainability) department. But the decades of risk management experience that the EHS/S function has, often goes unnoticed because of the historic focus on regulatory compliance.
In many organizations, the EHS/S function is more mature than the broader NFRM function. The challenges that EHS/S has had to address closely parallel the NFRM challenges, such as: comprehensive risk assessment; increasing employee engagement; breaking down silos; developing reliable frameworks; and developing meaningful metrics.
The EHS/S function and its professionals have well-developed structures and skills that can be used to address the accelerate development of the risk management function. This could be bad news for some readers who are worried about more work. On the other hand, it can be viewed as an opportunity to make a significant contribution in your organization.
Consider these EHS/S structures, practices and skills:
- EHS/S departments engage with every operational function in the organization;
- They have expertise in understanding regulatory compliance and “beyond compliance” approaches;
- They have unique sets of data that quantifies and measures a wide range of operations
- They have experience breaking down organizational silos and strength in generating engagement from the C-Suite downto the plant floor;
- They have the ability to analyze data used to predict outcomes;
- They have the skills to design and employ new systems within the various operations of the organization;
- With a robust EHS/S management system, they have a platform to build a strong ISO 31000-based risk management framework;
- EHS/S auditing functions are mature and can support evolving risk management performance measurement activities.
Possibly the most valuable of the above is the ability to quickly develop a strong risk management framework (or you could say, a Risk Management System) using the existing integrated EHS/S management system. The blending of ISO 31000 into a mature ISO 14001/OHSAS 18001 EHS/S MS, provides the strong risk management framework that can unify a fragmented risk management function.
Strictly speaking, ISO 31000 is not a management system. The intent of this standard is to augment existing management structures to achieve risk management goals. Not only can an ISO 14001/OHSAS 18001 management system provide a strong risk management foundation, when augmented with ISO 31000, the converse is also true. A 14001/18001 integrated system can be turbo-charged by folding in key elements of 31000, such as 31000 pieces on “establishing the context” (Sec. 5.3) and with EHS/S integration in an organization (Sec. 4.3.4). Finally, 31000 provides the lens through which a wide range of “risks” can be identified and controlled (Sec. 5.4 and 5.5), such as those associated with social responsibility, sustainability, and supply-chain issues.
When it comes to developing a framework for addressing non-financial risks, what has been your company’s approach? What other lessons do you think we could learn from the evolution of the EHS/S function?
Dr. Charles Redinger is a principal with Redinger EHS in Harvard, Mass. He has been at the forefront of environmental health & safety (EHS) management system and performance measurement research and methods development since the early 1990s. He has been a member of the US TAG to ISO 31000 on Risk Management. He has also served as the Chair of the AIHA Risk Assessment and Management Committees, and is currently serving as a national Director for AIHA. He is a Director at the Center for Safety and Health Sustainability and is a Certified Industrial Hygienist.
Increasing EHS Value in Tough Economic Times
Mark Posson
Can we do more with less? Absolutely! This tough economy is affecting all aspects of an organization and environmental management is not immune. Today’s reality in most organizations is stagnant or declining resources and a continuing mandate to increase environmental performance. We need to resist the tendency to pull back in tough economic times and instead be introspective and improve the way we execute. We can free up the resources to meet the demands of expanding requirements by continually improving our business processes. The increased efficiency will free up resources and the increased effectiveness will boost performance and stakeholder value.
Strategically, what processes provide the greatest value to our stakeholders? Where can we get our biggest return for the time invested? These basic questions will help prioritize your improvement targets and possibly identify processes that can be eliminated. A ranked list of processes for improvement will guide your pace of change and tactical execution.
Tactically, the simplest path to improve a process is to follow the elements of lean:
- Identify the value to the stakeholder (your customers)
- Determine the sequence of activities (current process flow)
- Identify the activities that create value
- Eliminate activities that do not add value
- Identify process inefficiencies and their cause(s)
- Eliminate the cause(s) of inefficiencies
- Create the new process (future process flow)
- Implement the new process
- Measure results
The steps are simple but often challenging to implement in light of day-to-day execution pressures. We can’t expect different outcomes by following the same processes. The investment in process improvement will provide the payback in better results with fewer resources.
What strategies do you use to do more with less?
Mark Posson is the former Director of Environment, Safety and Health at Lockheed Martin Space Systems Co. and the current Chair of the city of Pleasanton’s Energy and Environment Committee. He recently began offering consulting services to help organizations improve their environment, safety and health performance.
Ergonomic Success Requires Leadership
Walt Rostykus
Over the years, I’ve met environment, health and safety (EHS) managers who are convinced that by driving safety and ergonomics through a grassroots approach, some day the initiative will catch on with supervisors, managers and company leaders as an infectious commitment.
“If you build it, he will come” may have worked for Ray Kinsella in the movie “Field of Dreams”, but let’s get real folks: This approach is a shot in the dark for quickly and effectively improving and sustaining safety and performance in the workplace.
Indeed, the key elements of leadership in maintaining an effective and sustainable ergonomic improvement process are no different than those of an EHS system, company culture, or any other aspect of a business. The bottom line is that leadership must occur from the top.
A wise person once noted, “What interests my manager motivates me.” This is the key to leading a safety and ergonomics process over time. Think about it: At work your priorities and activities are guided by how your manager tracks and measures your performance. It is our experience that when managers, engineers, supervisors and employees have a clear understanding of their involvement in the effort to improve workplace ergonomics (and they are held accountable to those expectations), effective workplace changes are made.
Yet leading an ergonomics process is not usually intuitive to many in top management roles. As an EHS manager, however, you are in a position to coach top management on the few things they need to do; simply put, they need to hold their direct reports accountable for ergonomics performance (see my prior blog on effective goals and metrics for ergonomics). The four most important things they can do to make sure this happens are:
- Set clear expectations (responsibilities, goals, roles, targets)
- Provide people with the resources, tools and training they need to meet their responsibilities
- Visibly and actively monitor and track progress
- Take action when expectations are not met
Fortunately this four-step approach is not foreign to managers and supervisors. They follow some form of these steps to complete work, build widgets and manage production. Leaders in safety should apply the same approach (accountability) to influence, guide and lead their organization to success. It’s all about planning, managing and following through.
Kurt, my climbing instructor from several decades ago, was a great illustration of how not to lead by example. His immortal words “Do as I say, not as I do” sent a mixed message. While he told us to wear the correct helmet and always climb while belayed, he climbed bare-headed and without a lifeline. He was technically knowledgeable, but clearly not a leader.
On the contrary, Dave Packard, Bill Hewlett and Bob Hall were true leaders, who set expectations for performance (including safety) and held people, including general managers, accountable for the quality and safety of their workplace.
Whether you base your company ergonomics program on Occupational Safety and Health Administration (OSHA) models, the Safety Management System, lean manufacturing or continuous improvement, strong and visible leadership by people in top management is critical for ensuring that engineers design tools to fit the first time; employee teams reduce exposure to work-related musculoskeletal disorders (WMSD) risk factors before injuries occur; and that employees adjust their own work stations to best fit them.
If improving ergonomics is a priority for your organization, does your top management team lead by example? Have they set performance expectations, goals, and clear roles? Do they track performance?
If not, what have you done to best prepare them to lead?
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.
