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Article # 0042

AN ENGINEERED APPROACH

TO

ES&H POLICY

by Robert (Bob) Langley, P.E

Introduction

          Most organizations have an Environmental, Safety & Health (ES&H) policy statement that addresses regulatory compliance and protection of personnel (employees and community), the environment and company assets. The challenge is to translate that normally general, goal oriented statement to tangible actions that make the Policy “come alive” and be a normal part of the daily routine throughout the organization. In other words, to “walk the (policy) talk” from the CEO down to the beginning roustabout. If this doesn’t happen, the policy statement, although usually a collection of high sounding words that makes a board of directors or company executives feel good, will languish on a bookshelf or website without genuine application.  If it doesn’t languish, the good intentions of employees to comply with the policy may be inconsistent, expensive, and short of the desired mark.

             Assuming some type of ES&H Policy statement exists, this paper is designed to provide guidelines on how to make that statement “come alive” in real life application utilizing tried and proven standard engineering principles. 

Know the Management and Organizational Culture

          It’s important to know where your current Board of Directors and/or the Executive/Management team is coming from on the matter of ES&H vision.  A good rule of thumb for a supporting policy statement is “don’t say it if you don’t mean it.”  In other words, don’t say things like “...we’ll be a leader in compliance…” unless your company plans to tackle emerging issues, be proactive and stay ahead of the curve—that costs money; or “…we will be in compliance with all laws, rules, regulations regardless of degree of enforcement”, unless the corporate culture will indeed support that stance, “through thick and thin.”  Also, it’s a good time to get a feel for how this process will integrate with ongoing business planning processes vs. being a “stand alone” effort (which usually doesn’t work long term.)

Assess the Existing Policy

          The first step, consistent with an engineering approach, is to objectively examine what’s currently available and its evolution.  How was the current Policy statement devised, by whom, when and why does it read the way it does? This can be very educational, especially if one is able to glean forensic information and valuable history from developers of the original statement. After a firm foundation of this understanding, then move forward to answering some of the following questions: 

• Does the current policy statement reflect the current regulatory environment?
• Does the current policy reflect upper Management’s ES&H vision for the organization?
• Does the current policy statement match the business needs?
• Do the following elements line up with the current organization?

                        -Scope

                        -Functional Responsibilities

                        -Procedures

                        -Related Policies, work processes, references & established practices 

How this is done is critical.  From the outset, this should not be perceived as a Corporate “ES&H Department” driven process.  Therefore, it’s suggested  a few qualified ES&H Staff lead/facilitate this  step, but a good  mix of  respected, interested and experienced line managers that will be affected by the policy be involved also. 

Caution:  Don’t let this Policy statement step become a tactical “how to” detailed compliance recipe. An average Policy statement is only about 1-3 pages long depending on the nature, complexity and size of the organization. Tactical details come later. Just stick to the basic policy statement and the accompanying items above. 

A final check off item on this step is to run the refined policy statement back by the Executive Management and confirm that it’s consistent with the values and vision they have for the ES&H process. 

As an example (since we need this later in this discussion) excerpt from the Policy statement may read as follows: 

“The Company will conduct its business in a socially and ethically responsible manner that protects the safety and health of all personnel, the community, and the environment and company assets.” 

That sounds good, doesn’t it?  But, what does that look like in real life?  As an affected manager, what am I supposed to do to comply with that statement?  Read on.

Define the Key Elements of the Policy Statement

          After the Policy is updated and refined, then form an extended “Steering Group” (may have some of same members as Policy Statement group) of qualified operating division representatives to define the generic Policy elements consistent across the organization. There’s a lot of different ways to look at this, but generally, these areas fall into the following categories, or “Key Elements” that support and provide more focus/detail for any ES&H Policy: 

• Compliance Assurance
• Community Awareness and Outreach
• Emergency Preparedness  and Response
• Energy and Resource conservation
• Legislative and Regulatory Advocacy
• Pollution Prevention
• Product Stewardship
• Property Transfer
• Safe  & Secure Operations
• Transportation and Distribution

If you go back to the example excerpt Policy statement in italics above, you can see how these Key Elements map into those words.

Note: A way to foster upper Management support is to designate senior Executive Management as a “champion” or a “sponsor” for a Key Element (across the organization) that particularly affects their functional part of the organization.

Define the Management Practices for each Key Element 

          The Steering Group sets the compliance tone for the entire organization by defining each Key Element in more detail as it supports and relates specifically to each part of the general Policy statement.  Each Key Element is broken down into its primary performance based statements called “Management Practices.” In engineering terms, these are the performance “specifications.” Depending on the Key element, these can number from half dozen up to fifteen or so.  For example, two of the Management Practices of the Key Element “Safe and Secure Operations” (which support the protecting personnel and assets part of the example statement above) might be the following: 

• Establish a system to report all incidents and near misses along with a process to identify root causes of errors and incidents. This involves investigating, reporting and taking appropriate action following each incident that results (or could have resulted) in an injury, illness, fire, explosion or accidental release. Also, it involves sharing relevant safety knowledge and lessons learned from such incidents within the company, the industry, the government and the community. Implement solutions using systems to track and analyze relevant data and measure improvement.

• Establish an effective access control system that at all times protects personnel and company assets by accounting for all employees, visitors, vendors and equipment entering and leaving the facility.  This involves qualified screening, validation of the person’s business with the company and monitoring his/her whereabouts at all times.

What Gets Measured Gets Done 

            Once the Management Practices have been defined for each Key Element have been defined, while the Steering Group is convened, it’s best to define how the organization’s performance and results will be measured. As any Engineer knows, “what gets measured, gets done”, and usually the converse it true also.  As a suggestion, the following metrics may be used in measuring status: 

Stage 1-No action yet underway

Stage 2-Evaluating Management Practices against company, local policies and practices

Stage 3-Developing plans to attain management practice

Stage 4- Plans underway to attain management practice

Stage 5- Management practice attained

Stage 6- Management practice reviewed and attainment validated

Where the Rubber Meets the Road

            This is where the detailed plans are made—at the affected work unit level.  After the Steering Group has done their job in developing this process and it has been rolled out to the organization (which is a topic paper unto itself) with proper Management/Executive preparation and support, the affected groups have to begin making their specific plans within the given Policy framework to define what attainment activities will be undertaken. Usually, this is best done initially by an internal workgroup team with a trained facilitator that understands the objective of the process.  Once the locals get the hang of it, they can handle it from there on out.

            For ease of discussion, let’s take two different facilities and talk only about the second bulleted Management Practice above.  Facility A is a smaller, remote storage and transportation terminal operation with 12 employees.  Facility B is a much larger manufacturing complex with over 50 plant personnel and several contractors daily. It is critical to the company’s operations and is near a 5,000 population city. There is considerable construction activity constantly as the facility is undergoing modifications and expansion. Both facilities operate 24/7.

            Facility A might define attainment (Stage 5) as follows:

                       
            By (date) the following will in place:

                        -Repaired all fencing

                        -Automated, card access gates

                        -Security cameras

                        -Office “ check in/check out procedure”

                        -Signs installed with instructions

                        -Personnel trained

            Facility B might define Stage 5 attainment as follows:

            By (date), the following will be in place:

                        -Two Guard Buildings installed- at front and rear gates of facility

                        -Hired qualified Security service

                        -Installed automatic gates and video monitoring

                        -Documented check in/checkout by person and vehicle

                        -Search Procedures in place

One can see where these plans will require financial and personnel resources, hence the need to consider in the business planning process. The common theme on any attainment plan is a tangible result tied to an expected completion date.

Critical Success Factors

          This can be a significant but worthwhile effort to “get everybody on the same page” for something as important as protecting people and the environment. However, it does require commitment and resources.  Factors critical to success are as follows: 

• A clear message from Management on what the ES&H vision is
• A clear message from Management that the Policy will be complied with
• A commitment to provide the resources to make it happen
• Ongoing, visible  Management Support
• A qualified ES&H Corporate Staff that can act as process consultant and leader
• Progress reporting (Stage) is regularly (at least annually) reported  to senior management level
• Progress is part of the annual performance evaluation process (that affects merit raises and promotability.)
• It’s not perceived as another Corporate driven “program” (although it may feel that way at first), but an ongoing, participative  “process”
• It’s not a stand alone effort…….it’s incorporated in business planning, performance reviews, daily work activities, and projects planning.
• Give it time……it’s not unusual to look at reaching Stage 5 on some Management Practices for 5 or so years.
• An exemption process if Key Elements/Management Practices not applicable

Conclusion

            Applying engineering principles including gathering data for the current status, objective evaluation of data, selection of the best options, defining requirements, establishing metrics and validation of results has a place in implementing an organization’s ES&H Policy. These activities, when practiced in a structured framework that’s commensurate with the resources and ES&H vision for that organization, can lead to ongoing compliance benefits.

Bibliography:

Protecting People and the Environment-Implementing our Policy 530 (Chevron Corporation-1992; not copyrighted)

Biography:

Robert (Bob) Langley, P.E. holds a B.S. Degree in Chemical Engineering from the University of Oklahoma. For over 30 years he worked for Fortune 500 midstream (natural gas processing) companies as Process Engineer, Plant Engineer, Plant Supervisor, Plant Manager, Supply and Distribution Manager, Supply Chain Manager and Environmental, Safety & Health Manager. As ES&H Manager, he had direct responsibility for guiding implementation of the Corporate ES&H Policy within his operating company as described in this article.

Article # 0042         TEST QUESTIONS:

1.  An ES&H Policy statement should contain ...

1. Scope

2. Functional Responsibilities

3. Procedures

4. All of the above

2.   Any policy statement should address protecting ...

1. People

2. Environment

3. Company Assets

4. All of the above

3.   Whose vision is important to understand before starting on this effort?

1. Management

2. The Human Resources Dept.

3. The Engineering Dept.

4. All of the above

4.   Most ES&H Policy statements can be supported by ten ...

1. Key Elements

2. Management Practices

3. Amendments

4. Articles of Confederation

5.   The activities under each Key Element are called ...

1. Sub elements

2. Management Practices

3. Key Job Responsibilities

4. None of the above

6.   “Attainment” is gauged on the metrics scale as ...

1. Stage 1

2. Stage 2

3. Stage 3

4. None of the above

7.   One characteristic of a valid Attainment Plan is ...

1. equality

2. a completion date

3. objectivity

4. All of the above

8.   A good way to gain upper Management support is to ...

1. Have the CEO to run the whole program

2. Designate Executive Managers to “sponsor” a Key Element

3. Have their Administrators send out a letter

4. All of the above

9.   What does ES&H stand for?

1. Ethics, Standards & Hierarchy

2. Earnings, Savings & Hope

3. Environmental, Safety & Health

4. None of the above

10.   Which of the following is NOT a Key Element for an ES&H Policy statement

1. Pollution Prevention

2. Emergency Preparedness

3. Management Practices

4. Energy Conservation

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