Carol Singer Neuvelt

Last week I traveled to Boston for NAEM’s Product Stewardship conference, where we discussed best practices for complying with new product-focused regulations, internal collaboration, managing supply chain data, and engaging customers and suppliers.

Like many sustainability initiatives, “product stewardship” is an exciting concept, with the potential to spur innovation and transform the structures on which our current industrial ecosystem is built. Whether your company defines product stewardship broadly as “green product development” or in terms of compliance with product regulations, it involves re-thinking the fundamentals of how the product was designed, produced and labeled.

This is easier said than done.

From the outside, finding out what goes into your products might seem pretty straightforward: First, you ask your product development or research and development folks to tell you what materials go into your products. Then, you find out where those materials came from and document that information.  Simply talking to your first-tier suppliers, however, will not likely yield the full answers you seek. For diversified manufacturers with global supply chains, product stewardship is an exercise akin pulling a loose thread on a sweater and seeing how long it takes to stop unraveling. Where does it end? And how far back “beyond the gates” is your company accountable?

In the overall history of manufacturing, the era of transparency is in its infancy. Our globalized manufacturing platforms operate on systems which were designed to be predictable, reliable and cost-effective. Introducing a new variable may be the next step in the evolution of proactive environmental management, but meeting the challenge of this paradigm shift will take time to accomplish. Companies are not yet accustomed to disclosing the information their customers and the regulations are now requiring; companies might not have data management systems adequate to meet the challenge; suppliers might not have the data their customers are seeking; that data may require third-party validation before it can confidently relied on; and, the transparency of that data may be associated with unintended business risks.

In other words, it’s a process. A process that has yet to be mastered.

Our recent benchmarking survey on the topic revealed that among the leadership companies who belong to NAEM, there is not a consistent approach to defining, managing or leading product stewardship efforts.  Given the systemic nature of this challenge, many companies have responded by creating a cross-functional team composed of representatives from environment health and safety (EHS), procurement, legal, research and development, operations and marketing. The outstanding management question companies are struggling with, however, is who should be ultimately responsible for the outcome of the collaboration?

It’s likely that each industry, each company and each business team will answer that question for itself. But the issue of accountability is yet another thread on the sweater, a reminder that like many sustainability initiatives, the product stewardship challenge involves as many questions as answers.

Dania Nasser

In April, Dania Nasser, a graduate student at Yale University and a member of NAEM’s Emerging Leaders group, sat down to speak with Michael Washburn, Director of Sustainability at Nestlé  Waters North America,  about why the company is supporting an innovative approach to recycling called extended producer responsibility (EPR).

DN: Michael, what exactly is EPR?

MW: Common in Europe and Canada, EPR requires industries, such as the beverage industry, to pay for the collection and recycling of their products once they reach the end of life. We hope to bring the financial responsibility of recycling back to the industry, while collaborating with municipalities to increase access to curbside recycling and recycling away from home.

In 2010, Nestlé Waters North America (NWNA) supported the launch of an EPR program in the Canadian province of Manitoba, featuring four key elements: curbside recycling, public spaces recycling, commercial/institutional recycling and a public education plan. Results thus far have been encouraging, and will provide key learnings for EPR in the U.S.

DN: Why does NWNA support EPR?

MW: At Nestlé Waters, we seek to capture and reuse every Polyethylene terephthalate (PET) beverage container, so we put ourselves on the front lines of advancing recycling, whether it is in the lab, the field or at the policy level. While PET containers for bottled water make up less than 1 percent of all U.S. municipal solid waste, much work remains to ensure these, and all valuable recyclable materials, stay out of landfills.

It’s really in our best business interest as well: EPR serves as a risk-reduction strategy around our materials. Volatile commodity prices are an issue for us, and the ability recoup materials can help stabilize our costs.

To evaluate how to get our bottles back for creation of recycled PED (rPET) bottles, we examined a variety of recycling programs and found we’d need a multi-pronged approach that includes institutional and commercial recycling, as well as curbside and away-from-home. We see EPR as the only way you can do it, by folding fees into a broad variety of packaging, isolating them – importantly, outside of government – and then using funds derived from those fees to meet recycling goals that are set by state government.

Speaking of recycling goals, we hope that EPR will help to double U.S. recycling rates for all PET plastic bottles to 60 percent by 2018, a Corporate Citizenship goal we set in 2008.

DN: Some states have redemption incentives for in place for people. Did you examine this approach as well?

MW: We don’t want to dismantle bottle bills, but we do want to out-perform them,   and so we are focusing our current efforts on non-bottle bill states. But there are other challenges to consider. Among other issues, bottle bills reinforce the notion that plastic bottles and beverage containers are the problem, when, in fact, these are only part of a broader societal problem in which too much valuable packaging material is going to landfills.

We want to have a deliberate, fact-rich dialogue on what EPR is and how it works, so we are working to launch EPR in states that don’t have a bottle bill, but have good recycling infrastructure and support in place, like Minnesota and Maryland. This will mean we can collaborate around EPR as a new model, without having to delve too far into the relative wisdom or merits of bottle bills.

In addition, we want to engage the kinds of stakeholders who traditionally support bottle deposits so they can come with us on this journey and understand that we can get higher rates of recovery with a different tool, and – from an environmental and efficiency standpoint – can ultimately out-perform bottle bills.

DN: What kinds of industry players and other stakeholders are you working with in support of EPR?

 MW: We’re working with a really broad range of stakeholder groups, including consumer product companies, beverage companies, various trade associations, commodity groups, private haulers, municipalities, state legislatures, environmental NGOs, grocery retailers, other retailers, the forest product industry and more.

I’ll share one example of a stakeholder group. Recycling Reinvented is a 501(c)(3) nonprofit organization committed to advancing recycling rates of waste packaging and printed material in the U.S. through an EPR model that would require brand owners to develop and fund effective recycling programs. We are directly supporting Recycling Reinvented’s efforts, both through funding and our CEO Kim Jeffery’s leadership as a member of the organization’s board.

In addition, many people are aware of a dialogue process facilitated by a group called Future 500 that has brought together 30 organizations to talk about the best attributes of an EPR program that could work in states in the U.S and how to craft a legislative package and a strategy to successfully pass that package. We’re going to try and move legislation in 2013.

DN: Obviously, you’re hoping for the legislation to be successful. What’s its best selling point from a societal and government perspective?

MW: This is really the most rational approach to what is a challenging dynamic around the disposal of valuable materials in this country. Taxpayers should be uncomfortable with contributing to a system that brings only a 30 percent recycling rate for plastic bottles. So this is deeper than our own interests in the issue. We’re going to see a louder drumbeat growing over time from the standpoint of commodity associations that want this material back, municipal governments who are fiscally burdened by the current system and stakeholder groups that think that companies should shoulder this responsibility. I think that’s where our broader culture is headed—more and more, companies are expected to take responsibility for their products, from the sourcing of ingredients to disposal of packaging.

Dania Nasser is completing a Masters in Environmental Management at Yale University. She is  Director of Environmental Affairs at a New York law firm specializing in environmental and construction law and a member of the Board of the Manhattan Chamber of Commerce Green Finance Committee. Ms. Nasser has an undergraduate degree in environmental engineering and a law degree. 

Parynaz Mehta

For healthcare products and pharmaceutical giant Johnson & Johnson, an environment, health and safety review is embedded within the new product development process.  This week we spoke with Parynaz Mehta, Senior Manager of Product Stewardship for the company’s Medical Devices & Diagnostics division to understand how product stewardship transforms sustainability principles into sustainable products.

GT: How do you define product stewardship at Johnson and Johnson?

PM: For us, product stewardship is making sure that we offer environmentally compliant and sustainable products to our customers, and we do that by looking at the entire life cycle of our products. So right from designing the product to be compliant, to picking the right type of materials to picking the right type of packaging to making sure that we try to offer our customers solutions for end-of-life type of issues, and making sure that we try to offer end-of-life options to our customers.

Product stewardship is just one pillar of the overall sustainability strategy, which also includes working with our suppliers and external manufacturers to expand the definition of sustainability beyond our fence. So we work in partnership with our suppliers and external manufacturers, and we also engage our internal customers in conversations around sustainability. So how do we get our own employees excited? And what can they do at the local level within our facilities for sustainability? We also engage with telling our sustainability stories externally. We engage with customers, we engage with nongovernmental organizations (NGOs) and other interested groups to talk about sustainability outside.

GT: What is the relationship between product compliance and product stewardship?

PM: Compliance is the first step of the product stewardship process. It’s like the foundation, the bed rock. The number one objective of our product stewardship team within medical devices and diagnostic team is to make sure that everything we design and everything that we put on the market is fully compliant.

GT: You said Product Stewardship is a team effort. Who is responsible for Product Stewardship at Johnson and Johnson?

PM: At the enterprise level, sustainability is owned by worldwide environment, health and safety (EHS). That’s the corporate department that drives sustainability and product stewardship. At the sector level, I lead the product stewardship for the Medical Devices and Diagnostics sector and I report in through the Senior Director for EHS.

GT: How have initiatives like product stewardship changed the relationship between EHS and product design?

PM: We work very closely with research and development (R&D) teams. Actually, at Johnson & Johnson, the EHS assessment, the ‘design for environment’ assessment has always been embedded in the R&D process. There’s a whole process map that R&D follows where it has certain stage gates, and for the past ten years or more, there has been a well-established stage gate for a design for environment review. (That name is a little bit misleading because it’s actually a product stewardship/EHS review.) We  have now re-branded the ‘design for environment’ term internally and are calling that our ‘earth words’ process. So when we do new product development, we have a stage gate when we engage with our R&D teams to have the conversations around “What’s in your product? What are the materials that we’re going to be using? What are the manufacturing processes? Where is this going to be manufactured? What’s the packaging going to look like? How is it going to be disposed of?” Wherever we can, we try to engage with those teams to drive the sustainability conversation.

Parynaz Mehta is Senior Manager of Product Stewardship for Johnson & Johnson’s Medical Devices & Diagnostics Supply Chain. She will be presenting on the impact of new product focused regulations at NAEM’s 2012 Product Stewardship Conference in Boston on May 9-10.

Alex Pollock

One of the greatest leadership challenges we face continues to be the unlocking of human potential in our workplaces. For the last decade I’ve read Gallup and Towers Perrin (now Towers Watson)  workplace surveys, which uncover data like “only 38 percent of employees believe senior management is sincerely interested in employee well-being” ; “only one in five employees is truly engaged, heart and soul, in their work”; and “nearly 38 percent of employees are mostly and entirely disengaged at work”.

What would an organization look like where passion abounds?

In his latest book, “What matters now” Gary Hamel  suggests we can learn from some things from Web culture, which is a “testament to the power of intrinsic rewards”. The Web compounds our passions, he believes, because online…

•  No one can kill a good idea
• Everyone can pitch in
• Anyone can lead
• No one can dictate
• You get to choose your cause
• You can easily build upon what others have done
• You don’t have to put up with bullies and tyrants
• Agitators don’t get marginalized
• Excellence usually wins
• Passion killing policies get reversed
• Great contributions get recognized and celebrated

“Organizations will never be fully capable until they are fully human”, proclaims Hamel.

What are ways that we can magnify rather than shrink human passion in the workplace? What are those attributes that you feel are essential to keep us “engaged” at work? What are our responsibilities and the responsibilities of  those in leadership roles to embed these traits in workplace culture?

If we want to change the workplace survey results we must all be the change we wish to see.

Rock Creek Park cleanup 2012

This past weekend I started my Earth Day celebrations with a Cub Scout-sponsored cleanup of one of the DC area’s greatest natural treasures – Rock Creek Park.  And according to my fifth-grade son, he and I have been participating in annual park clean-ups since he entered elementary school.

What is special in this seemingly ordinary experience is that to him, Earth Day is a normal, annual ritual.  While he was running to join the others rock-hopping across the narrow bend in the creek, I overheard him say, “My mom works to take care of the environment all year round.  Earth Day is a big deal around our house and we’ve got a lot of activities planned.”  Those words were uttered with both nonchalance and pride.  What a difference a generation makes.

Earth Day is every day at NAEM.  Each of us believes that in fulfilling the association’s mission of empowering corporate EHS managers with knowledge and practical insight, we are making a difference in helping the planet.  The staff at NAEM is joined together by a shared values orientation, and we are proud to support a community of professionals who work hard to meet the ethical obligations for compliance, reduce their company’s environmental footprint and help to make workplaces safer and healthier for their fellow employees.

But even though we have chosen to work at place that reflects our personal beliefs, the weeks around April 22 are especially fun for our staff.  Last year we created some wonderful videos from our Green TIPS Guide. This year we’d like to share with you some of the ways our personal practices reflect the work we do at our jobs.  Whether it’s our passion for the outdoors, rehabbing an older home or riding a bike to work, I hope you will enjoy the NAEM facebook page and we welcome your pictures and stories of Earth Day celebrations.

As I was walking back from my morning of playing in the river beds, walking on logs across the creek and following my son holding a full bag of garbage, this thought came to my mind:

We pay attention to what we value…. We value what has meaning to us... That meaning comes from our heart, our community, and our experiences.

I hope that you will get to celebrate Earth Day in your way, and I encourage you to commit yourself to taking action every day.

Walt Rostykus

While working and benchmarking with a wide variety of companies, I hear a range of interpretations of what constitutes an “ergonomics program.”  Unfortunately, the term is being used to describe a mix of approaches (in addition to ergonomics) to managing musculoskeletal disorders (MSDs).

Several leading organizations are in the process of evaluating and changing their programs to simplify, improve focus and improve efficiencies in addressing and preventing MSDs. Currently, there are five general, but very different, approaches used to manage MSDs.  Companies use a few, some, or all of these to reduce losses resulting from these types of injuries.

1.     Change the Work and Workplace: This approach focuses on the design of new jobs, or changes to existing workstations, tools and equipment to better fit the population doing the work.  This is occupational ergonomics, which has been defined by the National Institute for Occupational Safety and Health (NIOSH) as “The science of fitting workplace conditions and job demands to the capabilities of the working population.  Ergonomics is an approach or solution to deal with a number of problems – among them are work-related musculoskeletal disorders.”

The most effective workplace changes are engineering controls, which are adjustments and changes in the physical workplace to ensure that the reaches, forces and distances are within the acceptable limits of the workforce.  This means designing the workplace to fit people, from the fifth-percentile female to the ninety-fifth-percentile male, to prevent exposure to MSD risk factors for most workers.  Engineering controls have been proven to be effective and efficient through research and benchmarking studies.

A secondary level of control is administrative controls, or changes to the administration of work, like job rotation, rest breaks and slowed pace.  Unfortunately, administrative controls do not reduce or eliminate the presence of MSD risk factors; they just reduce the exposure time.  They can also create additional work and challenges for managers and supervisors as they shift people between work task assignments.

Both of these types of controls are best supported by ergonomists, engineers, and professionals qualified in ergonomics.

2.     Change the Capability of the Person: This approach is based on trying to change the capabilities, fitness and stamina of the individual doing the work.  This is an element of fitness and wellness programs, and includes stretching, exercise and conditioning.  The focus is on changing the individual employee and is dependent upon the willingness and participation of people, as well as their existing physical condition.

Although some organizations mandate stretching before and during work, many find it a challenge to get people to participate in stretching and wellness programs.  In addition, company-mandated stretching programs have not been proven to be effective in preventing MSDs.

Unfortunately, employers have limited influence on the personal health and wellness of their employees, and have no control over pre-existing conditions.  This approach is typically supported by fitness trainers/specialists, physical therapists and occupational therapists.

3.     Change how the Person Performs the Task: This approach is based on getting people to behave differently in hopes of reducing exposure to MSD risk factors.  This is behavioral modification, and may include behavior-based safety programs, training and awareness campaigns, and use of body mechanics.  This requires people to change their perceptions of work and risk, and change how they perform work (consistently throughout the day, week and their careers).

Even when behaviors do change, they rarely have a significant impact on preventing exposure to MSD risk factors.  Managers have expressed their frustrations on “getting people to use safe working practices.”  This approach is typically supported by behavioral safety professionals/programs, training and fitness trainers.

4.     Fit the Person to the Task:  In this approach, the focus is on the individual employee (or candidate), measuring their physical abilities (strength, reach, range of motion), and matching their individual capabilities to the demands of work tasks.  This is accomplished by conducting a Functional Job Analysis and Pre-Work Screening to match the results to Functional Job Descriptions.

It requires an investment in performing tests on each employee and the time to match them to the physical demands of a task.  This practice was in favor in the 1960’s through the early 1980’s but appears to be waning.  It is our experience that 15 to 30 percent of U.S. companies still practice this approach. Companies in which manual material handling and field tasks are common typically have these programs in place.

Physical therapists can provide valid test methods to help match the capabilities of an individual to the physical requirements of a task.

5.     Fix the Person: When people experience an MSD or sprain/strain injury, they must be diagnosed and treated, and then managed in their return to work.  This is medical management, a reactive program to reduce the losses due to injuries that have already occurred.  The need for good medical management is totally dependent on the exposure to MSD risk factors in the workplace and the effectiveness of the ergonomics, fitness and job placement programs in place.  A medical management program is best supported by health care providers (nurses and doctors) qualified in occupational health.

So, how does your organization manage MSDs?

What approach or approaches do you use?

What has worked for you and what hasn’t?

What changes have you made to improve management of MSDs?

Sasha Bailey

I recently attended a sustainability-focused event, and while in line for my cup of Fair Trade coffee, I overheard a gentleman say, “This whole carbon footprint thing is really over.”

My first instinct was to seek shelter from what I knew would be a verbal onslaught of statistics hurled at this poor soul from fellow event attendees. However, being a sustainability-focused gal (and wanting a bit to hurl some statistics myself), my second thoughts were of disbelief and concern.

Is this what those outside of the small world of professional sustainability believe? Is this the rhetoric of a headline reader? (You know, those who read only the headlines and feel they have absorbed the current state of any issue sufficiently enough to have an opinion on it? You have talked with them before.)

From where I sit – still receiving CDP supplier requests, endless surveys and forms to fill out – the answer is that “this whole carbon footprint thing” is far from over. Perhaps, the issue is that the more mainstream something gets, the less we feel that the general public needs to be educated about it.  It might not be sexy that the majority of businesses find it common practice to fill out forms reporting their emissions, electricity use and water consumption, or that there are even whole departments or positions created for this very purpose. But it is reality. And maybe we should communicate this more often to the general public.

How do we make sure they understand that tracking our collective carbon footprints is not dead, but now a formal corporate process? I think the key is transparency.

Once we move from sustainability pages or sustainability reports to completely integrated sustainability data, it will be impossible to miss the facts. Right now, every website visitor or annual report reader can opt-out of sustainability information by simply foregoing those sections or links, but once integrated reporting takes hold, it will be there – no escaping or ignoring it. Carbon footprint will be right next to the profit and loss, which will make it virtually unavoidable.

What do you think? Do you think sustainability professionals should do more to keep the broader world updated on what we do day- to-day?

Sasha Bailey is the Strategic Communications Manager for ThyssenKrupp Elevator-Americans Operating Unit, where she  is responsible for creating and implementing high level communications strategies for all business units within the Americas as well as acting as the press and media liaison. 

Mark Duvall

On March 26, the Occupational Safety and Health Administration (OSHA) published its updated Hazard Communication Standard (HCS). The new rule, which applies to all hazardous chemicals, has been harmonized the Global Harmonization System (GHS) and will affect all companies that make, transport or use hazardous materials. Mark Duvall, Principal at Beveridge & Diamond P.C., has been following the HCS since it was a proposal in the early 1980s. We caught up with him this week to learn more about the updated rule and to understand its potential impact.

What’s the genesis of this latest HCS update?

OSHA adopted the HCS in 1983 and since then they’ve made a number of adjustments to it. They made the latest round of changes for two reasons.  The first is because the GHS is out there and the United States wants to harmonize its hazardous communications with those of other countries for the promotion of international trade. The second is that the agency believed that GHS would represent a clear improvement in the hazardous communication standard and thus help protect employee safety.

What is the GHS?

In 1992 the United Nations Conference on Environment and Development issued a mandate to develop a globally harmonized chemical classification and labeling system.  It adopted the GHS in 2003. The standard was intended to create a common system for hazard communications. At the time, the lack of consistency across countries was a burden to international trade.

The GHS applies to hazardous chemicals. It doesn’t apply to articles, or products that have a fixed shape, which are not intended to release a chemical.  There are also exemptions for certain kinds of chemicals that are subject to detailed regulation in specialized areas. So drugs, toy additives and pesticide residues in food ‘at the point of intake’ are not covered by GHS. It does, however, apply to worker exposure and transportation of drugs, food additives and pesticide residues in food.

It’s important to note that the GHS is a hazard-based system designed for trade; it’s not a risk-based system. Each company in the supply chain must consider its own risk and exposure conditions and decide on risk abatement measures.

How does OSHA’s rule compare to the GHS?

Let’s begin by talking about the three main elements to the  GHS:

1. The classification system: The GHS has identified physical hazards, chemical hazards and environmental hazards, and classified them by defining them and defining different categories within each hazard class with objective criteria. Once a classification for a chemical component has been determined, you then need to classify the mixture to which it belongs. Under the old OSHA standard, there was a pretty simple rule for determining the hazards of a mixture. The mixture was determined to have all the health hazards present if they had it at .1 percent or greater, with no regard to dilution. And that ran into a problem with acute toxicity for example if you took something that was acutely toxic at 100 percent and dilute it down to 5 percent, it might not qualify as acutely toxic anymore. What GHS does is it provides guidance on how to calculate the hazards of a mixture depending on the particular hazard categories of the various components and their proportions in the mixture. And there are different approaches for different kinds of hazards. It’s more complicated, but it’s generally regarded as a more accurate system than the old OSHA system.

2.  Labeling: Under the GHS there are multiple things that must appear on the label: the product name, the company’s name address and phone number, the standardized hazard statement, a pictogram and a precautionary statement. Under the old OSHA standard, you could express a hazard using any statement you wanted. Under GHS, there is a prescribed hazard statement assigned to each hazard category. There’s also a requirement for a pictogram, or a symbol conveying a visual idea of the hazard. A precautionary statement is what you should do in response to this hazard information (e.g. first aid instructions, personal protective equipment). And finally, there’s a requirement for a signal word. One is ‘Danger,’ the other is ‘Caution’. This is all different from the old OSHA rule, which required only the name and address, the name of the product and “appropriate hazard warnings” (which led to very different descriptions of the hazards for the same product).

3. Safety Data Sheets: A safety data sheet is a written compilation of information about the hazards of that product. In industrial chemicals, there is a list of data elements that have to show up. Under the old OSHA standard there was no required format for that. Now, under GHS and now under OSHA, there’s a prescribed format for the disclosure on the safety data sheets. GHS does not use the term ‘material safety data sheet’, and OSHA is adopting that language so MSDSs will now be called Safety Data Sheets (SDS). There’s a standard format and there’s also specific information that has to be included in each section.

What are some of the differences between the GHS and the updated HCS?

OSHA has not completely taken GHS. There’s a whole set of environmental hazards that are classified in GHS, which are not included in the new OSHA rule because the agency doesn’t have statutory jurisdiction. However, OSHA does require companies to include the section heading for environmental hazards; the hope is to encourage voluntarily disclosure of that information.

OSHA also adds some requirements that focus on the workplace where chemicals are present and where there is exposure potential.  It requires training, it requires a written hazard communication program and it requires labeling of containers and chemicals in the workplace. Because GHS focuses on trade, it doesn’t really address the occupational exposure aspect.

The OSHA rule also differs from GHS in its classification requirements. Under the old OSHA standard, you simply had to indicate that something was acutely toxic. Now, under the harmonized rule have to classify the hazard of acute toxicity and put it into one of several buckets. Rather than adopt all five GHS categories, OSHA omitted the lowest toxicity level because it concluded that it wasn’t appropriate to in a worker protection context.

When does the new OSHA rule go into effect?

The rule goes into effect on May 25, 2012 but compliance will take place in stages:

• Dec. 1, 2013: Deadline for training employees on the new label elements. Companies will start transitioning to GHS and they need to train employees to understand the new label warnings, particularly the pictograms.

• June 1, 2015: Classification, labeling and the SDS requirements. This is the same date that the European version of the GHS goes fully into effect. Distributors, however, may continue to ship products with the old labels until December 1, 2015.

• June 1, 2016: The other workplace requirements take effect.  These include requirements for hazard communication program and training on newly identified hazards. Between now and then, companies can comply with old rule, new rule or with both.

Mark Duvall is a Principal with Beveridge & Diamond, P.C. in Washington, DC, where he heads the law firm’s chemicals practice, as well as its FDA and OSHA practices. He will share his advice during NAEM’s upcoming webinar, “Preparing for the OSHA’s Globally Harmonized Hazard Communication Standard” on April 24.  

Bruce Klafter

As most of us know by now, in February, 2012 the Fair Labor Association (FLA), a multi-stakeholder organization focused upon workers’ rights, inspected three large factories in China, where Foxconn assembles products on behalf of Apple, probably our country’s most iconic brand manufacturer.  The report that was issued is interesting reading and offers some lessons that any business would be wise to learn and apply:

• Listen to your workers:  In the health and safety area, the FLA found that workers were alienated from safety and health committees, and had little confidence that management would address safety issues.  Keeping in mind that the scale in this case is unprecedented (i.e. FLA surveyed 35,000 employees out of the 179,000 working at these three locations!) the challenge of uncovering EHS issues is one that EHS professionals and management confront all the time.  It is virtually impossible to identify issues without the assistance of line workers, and workers will report issues only if they believe there will be no retaliation and that corrective action will follow.  In this instance, Foxconn has agreed to assure  the election of worker representatives without management interference, something that was lacking and that prevented open communication about EHS issues.
• Compliance can be hard, but the alternatives are generally worse:  The principal problem that precipitated these audits and that FLA confirmed was widespread at Foxconn is noncompliance with Chinese law and voluntary code prescriptions for hours worked.  Chinese law limits work to 40 hours per work and 36 hours of overtime a month, meaning a workweek should generally be no more than 49 hours. Foxconn workers were found to regularly work 60 hours a week or more.  The causes of excessive working hours are manifold, including a desire on the part of workers to get as much overtime and compensation as possible, and the solutions are going to be extraordinarily difficult. Foxconn has pledged to comply with the law and to maintain compensation for its workforce, necessitating the hiring of tens of thousands of new workers.  Given the amount of bad press this situation has created for Foxconn and Apple, it is no wonder that many are calling this Apple’s “Nike moment”, meaning the moment where it has been forced to meaningfully confront poor working conditions in its supply chain.  Apple was by no means sitting idly by while these violations persisted, but it was unable to devise a solution even with knowledge of its existence – an alarming state of affairs for any manager.

The kinds of issues disclosed by the FLA report are unfortunately endemic in China and other parts of the world, and are by no means confined to Foxconn and Apple, or even to the electronics industry.  Hopefully the attention generated by the situation will create some positive momentum for lasting change.

What do you think about the potential impact of this situation? Has it provided an opportunity for renewed conversation about EHS in your company?

Bruce Klafter is head of Corporate Responsibility and Sustainability at Applied Materials, Inc., where he leads the effort to fulfill the company’s commitment to sustainability in the design and implementation of business strategies and worldwide operations.

Joanne Schroeder

So you know you need an EHS MIS, but the question you’re probably asking yourself is, “Where do I start”?

Whether you need a system to collect and report sustainability metrics, capture incidents, or facilitate compliance, the process of identifying the right tools is complex yet similar in nature.  What we’ve noticed time and time again is that many EHS professionals often begin the process by focusing on the technology. This means perusing vendor websites, attending webinars etc. and, before long, find themselves receiving calls from software sales representatives. The momentum this process creates continues to sales demonstrations and ultimately a vendor selection.

Unfortunately, this scenario often occurs without EHS professionals ever  having documented exactly how their team operates and what they want this software to do.

What I’d like to emphasize in this conversation is that many of our top recommendations on where to start, ultimately relate back to the “people, process, technology” triangle.  The people, process, technology triangle underscores the importance of looking beyond technology as the sole (or even primary) factor in facilitating change.  Software is an enabling tool.  Sometimes we select software to embrace embedded best practices.  But often we don’t.  Sometimes we select software based on a prioritized “best-fit” with defined requirements. But sometimes we don’t.  Clearly developing a prioritized list of defined requirements with stated and measurable objectives are critical first steps to selecting the “best” technology for your company.  However, beyond technology, the people and process considerations are of equal importance.

Unless your company culture is “command and control” (which is usually not the case in today’s world) it is essential that company staff are emotionally bought in and invested in the technology solution. Opposed staff can quickly derail even the best of technology solutions.  Including a wide array of staff in specifying requirements, listening to and documenting wants and needs, polling and gathering general input, is absolutely critical to a successful rollout.

From a process standpoint, technology can enable EHS workflow if, and only if, these work flows have been established, understood and at least minimallydocumented.  If not, you will find yourself with no other choices than to embrace the workflow enabled by the software.  While this solution may work some of the time, it won’t work if you have not consciously made this choice and are just being dragged along.

For those of you who have been through the EHS MIS selection process, what is your advice for how to begin this internal dialogue? How much time did you set aside for the planning process?

Joanne Schroeder is a founding partner of E2 ManageTech, where she is responsible for project management, system solution design, systems implementation, quality control and business development.  She will be sharing her advice on the “Top 10 Things to Consider when Selecting an EHS MIS” during NAEM’s webinar on the topic April 18.  E2Manage Tech is a member of NAEM’s Affiliates Council.