Leadership engagement and commitment is critical to the success of integrating multiple systems because organizational leadership is responsible for ensuring that appropriate resources are allocated for needs such as a trained workforce, procuring software to support the EHS/ESG management system, ensuring the safe transfer of data and information into new systems and educating users of the new system through training programs. Visible leadership engagement is also vital to the success of an EHS/ESG system integration. Their visible and demonstrated commitment and ongoing support of the management system process highlights their focus on continual EHS/ESG performance improvement which in turn helps shape the organization’s EHS/ESG culture going forward.
Organizations can realize many benefits from integrating their EHS/ESG management system across the entire organization. Examples of benefits include aligning a stronger safe workplace culture, consistency across all business segments regarding EHS/ESG expectations, goals and objectives and consolidating the components of the EHS/ESG Information Management System (IMS). This IMS effort includes:
- Reduction in software and vendor costs
- Elimination of duplicate, and potentially contradictory, data that could be contained in multiple systems
- Improved system maintenance efficiency by reducing the number of systems and datasets
- Improved quality achieved by integrating EHS/ESG information with the organization’s human resources employee data
- Elimination of organizational silos by standardizing the way that EHS/ESG information and data are collected, managed and visualized
- The improved efficiency in reporting to corporate leadership and regulatory bodies by having a single repository of EHS/ESG information
While the benefits of integrating EHS/ESG management systems are well-known and valuable to the organization, the process for achieving integration must be well-planned and resourced and must have senior leadership support. This article explores the traits, implementation steps and benefits of a successful EHS/ESG management system integration and touches on the potential roadblocks that can stand in the way.
Components of an Integrated Management System for EHS/ESG Risks
The components of an integrated EHS/ESG management system generally follow International Organization for Standardization (ISO) element requirements for specific standards such as ISO 9001, ISO 14001, ISO 45001 and ISO 50001. Generally accepted components of such a system include:
- Policy and Vision Statement
- Leadership Engagement and Commitment
- Organizational Planning
- Roles and Responsibilities
- Support/Resources
- Risk Management and Controls
- Performance Evaluation and Improvement
Companies that develop their own internal standards to match their specific company culture, industry or client requirements may have different or additional elements or may place greater emphasis on a specific element. For an example, a company in the chemical industry will place greater significance on chemical exposure risks in its hazard identification process as an important component of their management system versus a logistics operations facility where chemical exposure is very low. In this scenario, the company can implement a process that includes a well-developed and executed industrial hygiene assessment program to ensure employees are properly protected and appropriate controls are in place and maintained.
Steps in Developing an Integrated EHS/ESG Management System
The steps for developing an integrated EHS/ESG management system are similar to the process for developing a specific management system. However, the evaluation of EHS/ESG risks are considered as a whole to prioritize and determine comprehensive risk controls to meet regulatory requirements and programmatic goals and objectives. Also, there are fundamental elements within a single management system that span across all management systems to create standards for performing integrated tasks (e.g., roles & responsibilities, management review, documentation, etc.). The preferred approach follows the Plan, Do, Check and Act (PDCA) model described by the ISO standards. The time-tested PDCA approach is used by thousands of organizations to achieve continual improvement.
Selecting the appropriate stakeholders for the design, development and implementation of the integrated EHS/ESG management system is a key step in the process to ensure a well-balanced approach. Representatives from various departments such as environment, occupational safety, sustainability and governance, as well as operations, maintenance and management should be included in the system design, planning and implementation. This approach gives each of the various groups the opportunity to shape the organization to achieve its goals and objectives. Barriers, silos or “turf battles” that can slow the integration process can be mitigated by having the various stakeholders work together on the design and planning. This approach enables a greater understanding of how each department benefits from the system, and thus promotes a greater spirit of cooperation and achieving the desired outcomes.
Development of a corporate EHS/ESG vision statement commits the organization and its resources, establishes clear goals and objectives and creates a path forward based on continual improvement that every employee can support. The vision statement must be shared routinely across the organization and posted for internal and external stakeholders to view.
Before launching into the integration process, it is helpful to conduct a self-examination of the organization to determine if it is ready to develop and/or integrate its EHS/ESG management systems. Some typical questions include:
- Why integrate the organization’s EHS/ESG management systems?
- How will the integration steps benefit the organization?
- What is our anticipated investment for the integration?
- How do we determine the return on our investment?
- What are the anticipated hurdles and barriers we are likely to encounter?
- How will we overcome the hurdles and barriers?
A design of the management system can generally follow the ISO approach or can be altered to match your company’s unique culture and business model. The design should incorporate all elements of the standard management system. One example of an effective integrated management system is the elimination of multiple systems for documenting and managing data and information. One system for the collection, analysis and reporting of all EHS/ESG data and information allows for data integration, comprehensive reporting features and enterprise-wide decision-making tools so that the company stays on course to achieve its goals and objectives.
After the team develops and approves the system design, resources can be assigned, information data management tools developed, and timelines established. All facets of the integrated EHS/ESG management system should be documented, communicated and implemented by the organization. These documents should be reviewed and tested by facility and operations staff prior to full-scale adoption. Training programs must also be developed and deployed so that applicable employees are aware of the EHS/ESG risk management protocols, control procedures and work practices and can implement them successfully.
Without periodic review of the health, effectiveness and alignment of the integrated EHS/ESG management system, the system may not provide the protection expected to control significant EHS/ESG risks. Periodic reevaluation of the EHS/ESG risks ensures that the management systems in place adequately track and effectively manages EHS/ESG risks. The data and information generated through the integrated management system will allow you to review EHS incident trends over time, which can be a great indicator of how successful the system is at preventing injuries and/or illnesses to employees and contractors, releases into the community and adverse impacts to the environment. This information can be communicated to organizational leadership and can drive future management system improvements.
Benefits and Value of an Integrated Information Management System for EHS/ESG Risks
A successfully integrated EHS/ESG management system is strengthened through the establishment of a well-designed and implemented information management system. Information provided through the EHS/ESG management system helps confirm compliance with applicable requirements, evaluate trends in EHS/ESG performance and provides management the feedback that the system is working. When it comes time to integrate EHS/ESG data and information into reports, the information can be pulled from a single repository that is standardized and used across all the organization’s facilities. This provides an improvement in efficiency and quality over traditional practices of synthesizing reports from many disconnected data and information sources.
Pitfalls and Obstacles to Avoid When Integrating an EHS/ESG Management System
As outlined above, the steps in developing an EHS/ESG management system are critical. There can be severe consequences, such as implementation cost overruns, slowed implementation due to re-design and adoption of a system that doesn’t adequately control EHS/ESG risks and thus doesn’t protect employee safety, the community and environment.
One of the most critical pitfalls to avoid is lack of organizational leadership support in the development and implementation of the integrated EHS/ESG management system. Lack of leadership support will likely result in poor outcomes related to inadequately designed and implemented systems. In addition, other factors impacting appropriate implementation includes adoption, training, adequate funding and an organizational culture that acknowledges and values the EHS/ESG management system.
Achieve New
Possibilities
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.
