Authors: Jim Wink and Kent Kading | mars 15, 2023

After Confirming the EHS/ESG Management System is Developed and Implemented as Designed, What Can We Learn and Influence for Continual Improvement?

Once we have confirmed that the EHS/ESG management system is developed and implemented as designed, how do we evaluate and improve upon the EHS/ESG management system’s effectiveness to protect the organization against experiencing moderate to high EHS/ESG risks? Recognizing that these EHS/ESG risks can lead to a significant and lasting negative impact upon the organization’s growth and prosperity, we must carefully monitor the system’s performance and take action for continual improvement. Specific attention needs to be focused on Management of Change (MOC) processes and the effectiveness of the controls to properly eliminate or significantly reduce and manage moderate and high EHS/ESG risks.

How Management Review Findings and Observations Can Correct Management System Structure Flaws and Implementation Challenges

It is critical to have a reliable “feedback loop” that informs you on the health and effectiveness of an implemented EHS/ESG management system. Required of any legitimate management system, periodic management reviews (i.e., at least annually) provide insight into the ability of the management system to control moderate to high EHS/ESG risks. Closely examining the findings and associated EHS/ESG risks of such a review will offer perspective regarding how the system is working.

For example, if the management review uncovers missed or lack of training for certain employees belonging to a specific job function or department with moderate to high EHS/ESG risks, is there a correlated increase in incidents around controlled processes that these employees haven’t been adequately trained to perform correctly to manage the associated risks? Or are there observations that Management of Change (MOC) events, critical mechanical integrity inspections and preventive maintenance activities have not been consistently performed and could lead to an EHS/ESG incident?

Performing this evaluation can provide the forensics necessary to see how these activities and outcomes are related. This presents the opportunity to prevent them from occurring and/or manage them effectively if they do occur. Once aware of these correlations, the importance of training, preventive maintenance events, etc. are heightened to leadership and applicable employees to ensure they are performed when they are required, especially if new employees are part of these significant risk activities or operation and maintenance of the related equipment. Much insight can be gained from a careful and critical review of findings and observations from a well-performed management review.

We can also look for any patterns in the findings and observations that may point to an elevated risk – whether previously identified or not yet discovered. Is there a higher frequency of findings associated with specific process areas, specific equipment, specific employee functions and/or individuals? These types of observations may reveal EHS/ESG cultural challenges that are not always noticeable or observed during a management review. Addressing EHS/ESG cultural issues are more challenging than the typical regulatory compliance or management system conformance missteps. EHS/ESG cultural reviews need to examine the employees’ interests, motivations and behaviors to engage within the organization – specifically on EHS/ESG risks and needs.

From our perspective, organizations that demonstrate routinely that they value their employees and engage them in EHS/ESG decision-making and program development tend to have the best workplace environments and outcomes to protect fellow employees, the community and the environment. Employees respond well when they are engaged in the processes to protect themselves, their coworkers and the community.

Just like the discipline needed to address critical process safety conformance and compliance standard findings, management reviews should also deploy a comprehensive root cause methodology to fully understand the causes and influences that lead to noncompliance, nonconformance and/or moderate to high EHS risk incidents occurring. Carefully evaluating the outcomes of a well-planned and executed management reviews can bring tremendous value to your EHS/ESG management system in the spirit of continual improvement.

GettyImages-2163457443-a

Evaluating Performance Using Data and Information to Achieve KPIs

In the last 10 years, it has become standard practice to establish key performance indicators (KPIs) for an organization to demonstrate and achieve progress within their EHS/ESG programs. KPIs may be external and shared with various stakeholders and/or they may be internal to help the organization focus of its important EHS/ESG goals. Typical examples of EHS/ESG KPIs includes:

  • Reduce total case incident rate
  • Reduce “near misses” count or rate (year-over-year)
  • Reduction in greenhouse gas emissions rate (year-over-year)
  • Increase the use of renewable energy sources
  • Increase employee engagement with EHS/ESG activities (culture improvements)
  • Increase inspections of internal EHS compliance requirements on key operations
  • Pursuit to achieve management system recognition through a governing body

Learn More About Our Integrated Approach

This insights post is a follow up to our recent white paper Managing EHS & ESG Risks Through Integrated Systems. TRC offers integrated EHS services that help organizations better manage EHS and ESG associated risks and improve performance at the corporate and plant levels.

Contact Us

3256d36b-woman-labor-and-factory-exterio-858529688

Organizations with established KPIs

Organizations with established KPIs need accurate, objective and reliable means to measure performance. Typically, the measurement and reporting of KPIs relies upon the Information Management System (IMS) that has been implemented to support the EHS/ESG management system and/or related programs.

It is important to initially and then periodically evaluate whether the information used to report the KPIs was properly established, objective, continuous or segmented and accurate. Understanding how all data and information that is gathered and used to report on the progress of each KPI and how they are measured will determine the confidence, dependability (reliance) and accuracy (appropriateness) of the information. This condition is critical in measuring EHS/ESG KPIs to inform the organization in whether it is making true progress or mislead by inaccurate information.

For each KPI, identify how the IMS was established to access information, which information/data, automated or manual entry, how that information is shared for inclusion and reporting and whether the information is monitored frequent enough to prevent noncompliance outcomes or EHS/ESG-related releases or incidents. Investigate how information that may become “unavailable” (i.e., during equipment shutdowns, startups or malfunctions) throughout the year is used or manipulated for use to accurately report on a specific KPI.

Through this investigation, you may discover that KPI outcomes are misleading or inaccurate, and that further rigor is needed to increase the accuracy of the data and information, especially for higher EHS/ESG risks. Creating a transparent process and procedure regarding how KPIs are measured (source of the information relied upon for the KPI) will provide the best outcomes for the organization. Critical to the success of any effective EHS/ESG management system is the timeliness and accuracy of the information and data used to make critical decisions and monitor performance of the EHS/ESG management system with confidence.

Embrassez le changement

Collaborez avec les praticiens testés de TRC

Contact Us

Partager nos perspectives

Nos praticiens partagent leurs idées et leurs points de vue sur les tendances et les défis qui façonnent le marché.

GettyImages-2154745535-a
Nouvelles

TRC Companies annonce vijay Gudivaka en tant que président de l’environnement et de l’infrastructure

janvier 30, 2024

La CVR a nommé Vijay Gudivaka président de ses groupes environnementaux (environnement, santé, sécurité et durabilité) et d’infrastructure

e672e729-four-businesswomen-in-discussion-1010836352
Aperçus

The Art of Industrial Hygiene Communication

juin 21, 2023

Understanding your own personal communication style and being aware of key best practices can help industrial hygiene professionals achieve better outcomes for their clients and advance their career development.

Petrochemical-Plant-Illuminated-at-Dusk
Mises à jour réglementaires

Changes to EPA’s Risk Management Program (RMP) Regulations Are Coming

avril 14, 2023

Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.

a6136fa8-gettyimages-1138436992
Mises à jour réglementaires

EPA Finds Trichloroethylene Presents Unreasonable Risk in Final Risk Evaluation

avril 6, 2023

On Jan 9, 2023, the United States Environmental Protection Agency (EPA) revised the Toxic Substance Control Act (TSCA) to reflect a new risk determination for trichloroethylene (TCE).

badabb4a-engineers-showing-his-colleagues-online-data-in-tablet-1207928632
Aperçus

Routinely Evaluating the Health & Effectiveness of Integrated Systems to Manage EHS/ESG Risks – Part 2

mars 15, 2023

Systematic monitoring and continuous improvement is important to achieve an effective EHS/ESG management system within an organization.

3256d36b-woman-labor-and-factory-exterio-858529688
Aperçus

Recognizing, Identifying, Prioritizing and Addressing EHS & ESG Risks

mars 3, 2023

A clear view and understanding of the environmental, health and safety (EHS) risks created by a business is paramount to its success and longevity.

2612967a-two-heavy-industry-engineers-1290244410
Aperçus

Routinely Evaluating the Health & Effectiveness of Integrated Systems to Manage EHS/ESG Risks – Part I

mars 1, 2023

Once established, an EHS/ESG management system must be routinely evaluated to ensure it remains effective to identify and control risks, as well as accommodate and adjust for changes that occur to/within the organization.

48ecc693-laboratory-safety-1440x810-1

QA and Chemistry Services

février 23, 2023

TRC offers many QA and Chemistry services including data usability assessments, limited and full data validation reports, quality assurance project plan preparation, selection of appropriate analytical methodologies and laboratory audits.

c3965908-stream-flowing-through-forest-1021703630-1440x960-1
Ressources

PFAS Fate and Transport: Conceptual Site Models

février 23, 2023

The conceptual site model describes site-specific sources, release and transport mechanisms, exposure media, exposure points, exposure pathways and routes and potential human and/or ecological receptor populations.

d7d3306b-firefighter-148304859-1440x960-1
Ressources

PFAS: Data Collection and Analysis Part 2

février 23, 2023

There are many PFAS-related challenges, such as changing regulations, toxicology, fate and transport, analytical methods, remediation, public perception and more.

6a7dcb76-pfaswebinar-1440x960-1
Ressources

PFAS: Sampling and Analysis Part 1

février 23, 2023

Sampling and analysis of Per- and poly-fluoroalkyl substances (PFAS) requires specific techniques and analytical tools to ensure data quality.

Sluice Gate Water Canal
Mises à jour réglementaires

EPA Publishes Effluent Guidelines Program Plan 15

février 14, 2023

The EPA announced updated effluent limitations guidelines under Plan 15, focusing on the evaluation and rulemaking process for per- and polyfluoroalkyl substances (PFAS) discharges.

c76f9026-trc-wisconsin-pfas-regulations
Ressources

PFAS: Remedial Approaches

février 8, 2023

Remediating Per- and poly-fluoroalkyl substances (PFAS) from the soil and water requires effective techniques and innovative technologies. TRC’s experts are well versed in several remediation strategies intended to remove PFAS and prevent re-exposure.

eadbdd0b-detail-of-white-smoke-polluted-sky-167231386-1440x960-1
Ressources

PFAS in Air: The Basics

février 8, 2023

Per- and poly-fluoroalkyl substances (PFAS) are a group of synthetic chemicals resistant to heat, water and oil. PFAS are widely detected in air as well as water and soil.

95cddf25-waupaca-wi-landfill
Ressources

Green and Sustainable Remediation

janvier 9, 2023

Green and sustainable remediation (GSR) can optimize remedial activities, minimize environmental footprints and reduce social and economic impacts.

9dd39045-hands-with-microplastics-on-the-beach-1150805328-1440x910-2
Ressources

Emerging Contaminants- Microplastics, HABs and Cannabis

janvier 9, 2023

Microplastics, harmful algal blooms (HABs) and cannabis/hemp can present health and safety concerns.

37306316-gettyimages-1169840024-1440x960-1
Ressources

Chlorinated Solvents 101

janvier 9, 2023

Chlorinated solvents are present in industrial chemicals and can post risks to the environment and human health.

230b3427-fill-the-airplane-with-fire-fighting-foam-613905646-1440x960-1
Ressources

PFAS: The Basics

Décembre 14, 2022

Per- and poly-fluoroalkyl substances (PFAS) are a group of synthetic chemicals resistant to heat, water and oil. These persistent chemicals have been found to be ubiquitous toxins in our environment.

7f19ecbc-abstract-pattern-of-aged-pvc-pipe-with-sun-lights-836200296-1440x858-1
Ressources

Petroleum Hydrocarbons 101

Décembre 14, 2022

This presentation defines petroleum hydrocarbons and covers the range of products and constituents that comprise petroleum hydrocarbons.

aerial-view-oil-refinery
Ressources

Advanced NAPL Site Characterization Tools

Décembre 14, 2022

Advanced NAPL site characterization tools can improve site understanding and remediation performance.

904ccb51-power-plant-in-urban-area
Mises à jour réglementaires

Proactive Enforcement is Key in the EPA FY2022-2026 Strategy

octobre 19, 2022

A core element of the EPA FY2022-2026 Strategic Plan focuses on environmental compliance.

c0e89bd9-gettyimages-644431672
Nouvelles

TRC Ranked No. 21 on Environmental Analyst’s Top 100 Environmental & Sustainability Consultancy Firms

septembre 20, 2022

RC Ranked No. 21 on Environmental Analyst’s Top 100 Environmental & Sustainability Consultancy Firms

f316520e-indoor-air-quality-1
Aperçus

Indoor Air Quality in the Workplace

septembre 1, 2022

Building occupants could develop breathing problems, cancer, skin issues, headaches, airborne infections and other health concerns.

GettyImages-1608527403
Aperçus

Preventing IAQ Issues Before They Start

septembre 1, 2022

Fixing problems before they worsen saves your building money and enhances safety. The same is true for indoor air quality. Learn more.

b585ce4f-ehs-white-paper-blog-e1677870757155
Aperçus

Optimizing EHS/ESG Information Management and Reporting Systems by Leveraging Innovative Digital Technology Solutions

août 10, 2022

A single, integrated enterprise wide EHS/ESG IMS can significantly improve performance and communicate progress towards organizational requirements and goals.

ec76f926-july-core-newsletter-image
Aperçus

Regulatory Compliance Items to Consider as Part of Transactional Due Diligence

juillet 19, 2022

Performing a limited environmental regulatory review can identify potential deficiencies with the environmental management of an acquisition.

04d8ea53-wastewater_photo
Aperçus

Integrating Sustainability, Digital Connectivity and Design Optimization in Wastewater Treatment Systems

juin 20, 2022

Some organizations rarely think about water and wastewater treatment, until there is a problem. American industry depends on the ability to treat wastewater discharges while complying with regulatory standards and addressing emerging contaminants. If wastewater treatment fails, our environment is negatively impacted, and companies are exposed to shutdowns, delays and fines.

GettyImages-1390962999
Aperçus

ESG vs. CSR | Differences, Definitions & Implementation

juin 19, 2022

ESG and CSR both address the need for corporate social responsibility in businesses but in different ways. Click here to learn more about ESG vs. CSR!

c20ba008-microsoftteams-image-18
Aperçus

Support an Integrated EHS/ESG Management System

juin 10, 2022

While a Phase I Environmental Site Assessment (ESA) is a common method for identifying environmental liabilities during transactional due diligence, the ASTM International standard for Phase I ESAs (E1527-13, with proposed E1527-21 awaiting adoption) omits regulatory compliance from its scope. For properties containing operations that may be applicable to environmental compliance regulations, performing a limited environmental regulatory review can identify potential deficiencies with the environmental management of the facility. A limited environmental compliance review typically evaluates the presence of material findings that may exist in a facility’s management of its environmental compliance requirements. Material findings are defined as a condition of non-compliance that could necessitate expenditures, not including attorney fees or regulatory agency penalties, in excess of a specified dollar amount or materiality threshold. The materiality threshold is based on the client’s risk tolerance and is often in the range of $50,000. However, this amount is arbitrary and can be revised as appropriate. Non-material deficiencies, those identified below the materiality threshold, would still require action but are within the client’s risk tolerance.

GettyImages-1330498048
Aperçus

ESG Environmental Criteria Explained

mai 6, 2022

ESG criteria involve many factors and moving parts. Learn about environmental ESG criteria and contact TRC to develop an effective ESG strategy!

GettyImages-479579560
Nouvelles

TRC Companies Pledges to Achieve Net Zero GHG Emissions by 2040

avril 26, 2022

TRC Companies, a digitally powered and environmentally focused global professional services firm, announced its commitment to achieve Net Zero greenhouse gas (GHG) emissions across its full value chain by 2040, aligning with the most ambitious aim of the Paris Agreement to limit global temperature rises to 1.5 °C.

b517ce45-manage-ehs-esg-risks-blog
Aperçus

How to Use an Integrated Approach To Manage EHS and ESG Risks

avril 20, 2022

WINDSOR, Conn. – TRC Companies, a digitally powered and environmentally focused global professional services firm, announced its commitment to achieve Net Zero greenhouse gas (GHG) emissions across its full value chain by 2040, aligning with the most ambitious aim of the Paris Agreement to limit global temperature rises to 1.5 °C. To drive accountability and progress, we also commit to the following 2030 targets: 50.6% reduction in company-wide Scope 1 and 2 emissions (offices and fleet vehicles) from 2019 levels. 25% reduction in company-wide Scope 3 emissions (business travel, employee commuting, and purchased goods) from 2021 levels. “As a climate solutions leader, TRC recognizes the urgent need to address climate change and its adverse effects on our planet,” says Christopher Vincze, Chairman and CEO of TRC. “We must lead the way in establishing sustainable business practices and support our clients in efforts to reduce their impact on the environment as well.” TRC has been setting and achieving goals to reduce GHG emissions since 2015. We have developed a transition plan to accelerate our progress that includes the following focus areas: Enhance energy management Expand renewable energy procurement Optimize fleet, including use of lower-emitting fuels and electrification Optimize business travel to ensure a reduced carbon footprint Prioritize sustainable procurement practices “These targets are ambitious but achievable,” says Karen Lutz, VP Corporate ESG/Sustainability. “TRC is committed to working with our clients to tackle climate challenges while aligning with climate science and achieving absolute reductions through our full carbon footprint.

ehs-digital-technology
Mises à jour réglementaires

SEC Releases New Proposed Rules Requiring Public Companies to Disclose Climate Risks

avril 12, 2022

On March 21, 2022, the U.S. Securities and Exchange Commission (SEC) issued its proposed rules for The Enhancement and Standardization of Climate-Related Disclosures for Investors which would require public companies in the U.S. to disclose information in their annual financial reports.

lumber-and-warehouse
Mises à jour réglementaires

EPA Issues Information Collection Request for Plywood and Composite Wood Products Source Operators

mars 17, 2022

EPA issued an Information Collection Request (ICR) to develop new emission standards for inclusion in the Plywood and Composite Wood Products (PCWP) National Emissions Standards for Hazardous Air Pollutants (NESHAP).

GettyImages-680444286-scaled
Mises à jour réglementaires

EPA Lifts Stay of Standards for New Lean Premix and Diffusion Flame Gas-fired Combustion Turbines

mars 14, 2022

The EPA Administration signed a notice to finalize amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Combustion Turbines

glass-chemical-containers
Mises à jour réglementaires

PFOA & PFOS As CERCLA Hazardous Substances: What Does This Mean and How Can You Be Prepared?

février 17, 2022

A plan to designate two per- and polyfluoroalkyl substances (PFAS) as “hazardous substances” under CERCLA was recently submitted by the EPA.

GettyImages-1724394793
Aperçus

OSHA’s National Emphasis Program on Heat-Related Illness and Injuries

novembre 3, 2021

On September 20, 2021 in an OSHA National News Release, OSHA published a memorandum establishing an enforcement initiative that is designed to prevent and protect employees from heat-related illnesses and death. This initiative, which develops a National Emphasis Program (NEP) on heat inspections, is an expansion of an already existing Regional Emphasis Program (REP) in OSHA’s Region VI, which covers Arkansas, Louisiana, New Mexico, Oklahoma and Texas.

GettyImages-1329706118-sm
Mises à jour réglementaires

NJDEP Implements New Jersey Environmental Justice Law Through Administrative Order

octobre 5, 2021

On September 22, 2021, the New Jersey Department of Environmental Protection (NJDEP) Commissioner announced the issuance of Administrative Order (AO) No. 2021-25 to implement New Jersey’s Environmental Justice (EJ) Law. This order is effective immediately, and applicants seeking to site new major source facilities, renew major source permits or expand existing facilities with major source permits (e.g., Title V air permits) in overburdened communities are affected. There are more than 4.5 million people that live within 331 municipalities that are overburdened communities in the state of New Jersey.

GettyImages-1264334838-1
Mises à jour réglementaires

OSHA’s Call for Comments on Mechanical Power Press Standard Changes

septembre 30, 2021

OSHA has recently published a call for comment regarding mechanical power presses. The reason behind OSHA’s request is that the American National Standards Institute (ANSI) consensus standard for mechanical power presses has been updated numerous times since the implementation of OSHA’s standard.

GettyImages-1460822484
Aperçus

OSHA Returns to In-Person Inspections As COVID-19 Restrictions Lift

août 4, 2021

The Occupational Safety and Health Administration (OSHA) is authorized by the Occupational Safety and Health Act of 1970 (OSH Act) to assure employers provide safe and healthful work conditions free of recognized hazards and by setting and enforcing standards and providing training, outreach, education and technical assistance. OSHA has recently announced the return to in-person inspections as COVID-19 restrictions begin to lift.

GettyImages-2155903870
Livres blancs/rapports

Managing EHS & ESG Risks Through Integrated Systems Today and Beyond

juillet 22, 2021

It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.

c2c1506d-james-wink
Jim Wink

Jim Wink is the Senior EHS Consultant with decades of experience delivering EHS services including: compliance assurance; management system development, implementation and optimization; sustainability services; mergers and acquisitions. For additional information, John can be reached JWink@trccompanies.com.

4f5cdd91-kent-kading-portrait-2019
Kent Kading

Kent Kading leads TRC’s Environmental, Health and Safety (EHS) Services across the organization. He is responsible for the planning, operations, execution and delivery of EHS Services performed by TRC EHS engineers, scientists and specialists to our clients. He has over 30 years of experience leading EHS permitting, compliance and management system services for clients world-wide. Kent has significant experience developing, implementing and evaluating multi-media EHS compliance programs and management systems for various industrial clients. He has conducted comprehensive compliance audits, environmental/health risk assessments, process safety management/risk management plan development and support and air and water permitting projects at a variety of industrial facilities. He also has provided industrial clients across the United States with a variety of EHS Services including: air quality permitting and compliance; wastewater permitting and compliance; stormwater permitting and compliance; hazardous waste management; EPCRA reporting and compliance; OSHA/state programs health & safety compliance with program standards, including confined space, lockout tagout, hazard communication, walking-working surfaces, electrical safety, hot work and other industrial safety programs. Contact Kent at KKading@trccompanies.com.