Is the Management System Implemented As Designed and How Do We Verify?
Once established, the 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. Remember, we have created the EHS/ESG management system to protect the organization against risks that could be significant to its growth and prosperity. As a result, high and moderate EHS/ESG risks must be well-understood and appropriately controlled to protect the organization and the communities where they are located. In addition, the information management system (IMS) supporting the EHS/ESG management system must be properly aligned, receiving and communicating the applicable information and data necessary to control EHS/ESG risks.
Having independent review of the EHS/ESG management system using competent and objective expertise will challenge it with no preconceived opinions or perspectives. An organization needs an unvarnished review that honestly reflects upon the current management system and its risks. Utilizing competent expertise to perform these reviews will test the mettle of the system. It may raise issues and present challenges to the system that will allow it to elevate to a stronger system that is more resilient to unplanned changes and continues to mature for the protection of the organization into the future.
There are specific activities that need the appropriate timing and sequencing to effectively evaluate an established EHS/ESG management system and confirm it will likely protect the organization from existing and future moderate to high risks. TRC has established a 6-part series that examines and evaluates the health of the EHS/ESG management system for appropriateness, effectiveness and adaptability into the future. Without an initial and periodic assessment of the health and effectiveness of the EHS/ESG management system and IMS performance, it may not provide the protection expected to control significant EHS/ESG risks for the organization.
The Management System’s Intended Scope, Functionality and Design
The development, implementation and maintenance of an effective EHS/ESG management system and aligned IMS (to manage an organization’s risks) are a significant and critically important investment for its future. To properly protect and nurture this investment, the EHS/ESG management system must be carefully evaluated initially. Is it being developed and implemented as designed? We then need to routinely assess the management system to ensure it is working to effectively manage the organization’s EHS/ESG risks over time and through applicable changes across the organization.
When evaluating the health and effectiveness of the integrated systems to manage EHS/ESG risks, we need to gain a clear understanding of the management system, including its intended scope, functionality and design. The scope will include the physical, organizational and functional boundaries of the management system. The functionality will describe how the organization intends to use the management system to achieve intended outcomes and key performance indicators (KPIs). The design will detail the key components and their interaction, such as policies, standards, documents and standard operating procedures. The design is typically aligned with a standard, such as a specific ISO standard or another industry-aligned standard to suit the organization’s needs and interests. Organizations will typically define their management system scope, functionality and design within a controlled document.
Compare the Design of the EHS/ESG Management System to the Implemented System
An initial and independent evaluation of the management system should be completed to verify the implemented system conforms to the organization’s intended scope, functionality and design. It is important to catch any gaps early in the implementation process versus their discovery after a serious incident. The evaluation should cover each element of the defined management system. If elements of the management system have not been developed and implemented, actions should be taken to track and close these gaps immediately. Upon closure of these initial conformance gaps, routine evaluations should continue to assess the health and effectiveness of the management system. Are we achieving our intended outcomes from the development and implementation? Are we effectively managing the EHS/ESG risks to the organization? It is recommended that the frequency of the independent evaluation is performed at least on an annual basis (perhaps more frequently at the initiation of the management system until it is established). Independence in the persons performing the review is important to eliminate bias in the system operations and maintenance activities.
Checking Critical EHS/ESG Risks to Verify Operational Controls Are Effective
The evaluation of the management system should transition from an initial check (e.g., do we have all the elements, as we defined and committed to developing, implementing and maintaining?) to a reoccurring routine evaluation focused on checking critical points for EHS/ESG risk management within the organization, specifically those moderate to high risks identified within the organization. Are our operational controls appropriate, in place and effective? EHS/ESG management systems provide a structure to manage EHS/ESG obligations, goals and conformance standards, but also to most importantly identify and control EHS/ESG risks. An independent evaluation of the management system can provide a fresh set of eyes to observe an organization’s activities, products and services and the effectiveness in their associated operational controls to manage EHS/ESG risks.
A routine evaluation can provide confirmation on the effectiveness of controls with moderate to high organizational EHS/ESG risks, or it can shine a light on missing or inadequately implemented controls. Is the organization experiencing incidents (including “near misses”) that involve moderate to high EHS/ESG risks? If yes, what have we learned when performing a root cause analysis on these incidents? Do we need to elevate the certainty of the controls to lessen the probability the risk could be realized? An organization can use this information to best focus its resources, including staff and capital, to further minimize organizational EHS/ESG risks.
Adapt to
Change
Partner With TRC’s Tested Practitioners
Sharing Our Perspectives
Our practitioners share their insights and perspectives on the trends and challenges shaping the market.
Changes to EPA’s Risk Management Program (RMP) Regulations Are Coming
April 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.
EPA Finds Trichloroethylene Presents Unreasonable Risk in Final Risk Evaluation
April 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).
Routinely Evaluating the Health & Effectiveness of Integrated Systems to Manage EHS/ESG Risks – Part I
March 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.
QA and Chemistry Services
February 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.
PFAS Fate and Transport: Conceptual Site Models
February 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.
EPA Publishes Effluent Guidelines Program Plan 15
February 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.
PFAS: Remedial Approaches
February 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.
Proactive Enforcement is Key in the EPA FY2022-2026 Strategy
October 19, 2022
A core element of the EPA FY2022-2026 Strategic Plan focuses on environmental compliance.
Optimizing EHS/ESG Information Management and Reporting Systems by Leveraging Innovative Digital Technology Solutions
August 10, 2022
A single, integrated enterprise wide EHS/ESG IMS can significantly improve performance and communicate progress towards organizational requirements and goals.
Integrating Sustainability, Digital Connectivity and Design Optimization in Wastewater Treatment Systems
June 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.
Support an Integrated EHS/ESG Management System
June 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.
TRC Companies Pledges to Achieve Net Zero GHG Emissions by 2040
April 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.
How to Use an Integrated Approach To Manage EHS and ESG Risks
April 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.
SEC Releases New Proposed Rules Requiring Public Companies to Disclose Climate Risks
April 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.
EPA Issues Information Collection Request for Plywood and Composite Wood Products Source Operators
March 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).
EPA Lifts Stay of Standards for New Lean Premix and Diffusion Flame Gas-fired Combustion Turbines
March 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
PFOA & PFOS As CERCLA Hazardous Substances: What Does This Mean and How Can You Be Prepared?
February 17, 2022
A plan to designate two per- and polyfluoroalkyl substances (PFAS) as “hazardous substances” under CERCLA was recently submitted by the EPA.
OSHA’s National Emphasis Program on Heat-Related Illness and Injuries
November 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.
NJDEP Implements New Jersey Environmental Justice Law Through Administrative Order
October 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.
OSHA’s Call for Comments on Mechanical Power Press Standard Changes
September 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.
OSHA Returns to In-Person Inspections As COVID-19 Restrictions Lift
August 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.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 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.
