Given the extensive research we have undertaken, and experience that our team at Enhesa have in this area, we are going to make some assumptions about you…
- You are a seasoned EHS (environment, health, safety) and/or Sustainability (and possibly even a Quality management) professional.
- You work for a multinational company that operates factories, sites or offices in many different countries around the world.
- You are in some way responsible for ensuring that a particular site; sites within a region; or all of your global locations – are doing their best to comply with locally applicable EHS laws.
- The chances are that your company has a (relatively) small corporate EHS team, who are based at your company HQ, and that you most likely have regional and then individual site personnel who are responsible for EHS management.
- If your company has its HQ in North, Central or South America – it is our experience that you will most likely have some form of corporate EHS audit program in place – whereby you will send in 2nd or 3rd party auditors to your global sites (or select, higher-risk) sites – and do a spot-check on their EHS compliance – either with corporate standards, local legal requirements, or both.
- If your company has its HQ in Europe, Asia, Africa or Oceania, our research shows your management of EHS compliance is most likely based on some form of management system standard – such as ISO 14001 or OHSAS 18001 (soon to be ISO 45001). As part of this approach your sites will be required to have some form of register of applicable laws in place and be able to demonstrate awareness with those laws, and be able to demonstrate compliance with them. You may, or may not, have a system in place to verify your compliance with those laws…
- Regardless of your approach, the people managing your company’s compliance with EHS laws are most likely not lawyers.
- Your team around the world will have many other EHS issues to manage in their daily life beyond compliance with the laws, or staying on top of regulatory changes. EHS compliance is an important component of any EHS program, but it remains a small part of a big puzzle. Your time and resources are precious and you need to balance what you spend your time on, based on the risks you face.
- You are under pressure to balance the peace of mind that your EHS compliance approach (whatever that is) with your departmental budget. Whether any of us like it or not, EHS is too often still considered an overhead…
- The final assumption is that you are open to improving and enhancing your approach to EHS compliance – to be more efficient and effective – at both individual site level – and all the way up to corporate…
How many assumptions did we guess correctly?
We hope to address each of the challenges you face, one-by-one throughout this series, with best-practice advice derived from over a quarter of a century of support to global industry!
Issues around employee turnover, the constant battle to justify resources (and save on them wherever possible) and how best to structure the EHS functions are familiar challenges to our clients. However, the starting point of any program needs to be the right people in the right roles. They need the qualifications, skills and importantly, motivation to do well. This is, of course, easier said than done and the EHS domain, in particular, has its own set of specific challenges in this regard. Sometimes the truth can be painful, and one of those challenges is that EHS is not always seen as the “sexy” career option.
To set the scene around some other challenges, we often hear variations on some, all, or a combination of the following situations regarding corporate EHS department structure:
- Your company operates a “lean” corporate department – perhaps with only a maximum of 10 people fulfilling responsibilities around Compliance; Continuous Improvement; Industrial Hygiene; Remediation; Sustainability; Security, Environment…or variations thereof.
- The Corporate EHS Department tends to be supported by a larger number of Regional or Business Unit leads – who may, or may not be – full-time EHS professionals.
- In global multinationals, this team will be often responsible for supervising and supporting site-level EHS representatives across dozens, or even hundreds, of manufacturing sites (as well as offices, warehousing, labs, etc.).
- Corporate/regional managers will not be local EHS regulatory experts- and in many cases, will not have local language skills – but they want to know that all their locations are, at the very least, doing all they can to be as compliant with applicable laws as possible.
- Site-level personnel are likely to have some awareness of the EHS laws that apply to them – but they are unlikely to be lawyers or have regulatory experience; will not have resources to stay on top of regulatory change and they have plenty of other important EHS-related tasks to fulfill other than compliance with the law.
- “Brain drain” – With staff departures (through retirement or other reasons), an organization can often lose a lot of knowledge and expertise, particularly when it comes to knowledge of EHS regulatory obligations and compliance practices.
- At the corporate level, EHS departments are typically staffed by professionals who have specialized in EHS following a career in (Chemical or Process) Engineering, Manufacturing, Quality or Security.
- At regional/BU level it will be a similar story, with managers often recruited internally having been in a site or country-level role previously.
- Most EHS positions require at least a college degree.
- EHS roles are difficult to fill by generalists as it is quite a specific subject-matter – many EHS staff may not have any EHS (or specifically EHS regulatory) experience.
- Most EHS-personnel across an organization will only deal with EHS on a part-time basis – and will have other responsibilities around Quality, Security, Sustainability and Facilities Management. As a result, people are asked to do a lot, often with limited time and resources.
- Turnover can be high – we have evidence from one of our clients that their EHS department has the second-highest rate of turnover of any department in their global organization.
- EHS can be seen as a “peripheral” function, and perhaps is not as attractive a career path as others for young graduates.
- Finally, it is worth noting that in large organizations, EHS can often be managed differently under different departments or divisions of the same company. This means that it can be hard to plan, hard to get a sense of overall compliance, and companies will struggle to have consistent visibility of their compliance status across all of their business units, operating locations and real estate (for example).
Drawing on our experience of working with corporate, regional and local EHS departments over the years, here are a few examples of how leading global companies address their EHS staffing and departmental structure problems:
- This is also a challenge in its own right! However, as much as you can influence this, there needs to be leadership from the top of the company – ensure that EHS is integrated into the business (right from the top, down to the bottom, and vice versa). The CEO and their C-suite sets the corporate tone, strategy and commitments. Although the C-suite often sit atop a huge organizational pyramid, the growing importance of corporate and brand reputation means that EHS is increasingly being heard at the top table. It is also possible to influence the views, and therefore priorities, of your company’s leadership by demonstrating the benefits, in real terms that your department brings to the organization’s bottom line.
- Avoid departments becoming victims of their own success (i.e. having budget cuts if accident/incident rates drop to the point where the perceived risk is less). Make your department visible by demonstrating that EHS provides assurance, reduces risks and keeps your name out of the media for the wrong reasons.
- Structure your EHS compliance program around an integrated management system (IMS) – to ensure continuity and clarity in case of employee turnover.
- Make it mandatory for people to manage compliance using the same processes and systems – if you want a truly standardized global approach, everyone needs to be on the same page.
- Regulatory compliance is not everyone’s cup of tea and they have many other tasks to stay on top. Where appropriate, outsource certain elements of your compliance program and give your teams the tools, knowledge and training they need.
- Implement a global minimum standard on compliance performance. This can be based on self-assessment and/or audit findings or close-out numbers, for example.
- Encourage and foster collaboration amongst facilities with similar operations and processes.
- Potentially get buy-in from facility personnel by assigning specific EHS tasks to personnel outside the EHS department.
- Many companies will hold regular internal EHS/HSE conferences when they get teams from different geogrpahies together to foster discussion, teamwork and learn from each other and outside presenters. This is a great way to bond and enhance your EHS team.
- Some of our clients have an “EHS Champion” program, where they will identify employees ‘on the shop floor’ who show a desire and aptitude for EHS. This can be a great way to enhance and guide people in their EHS careers.
- I have spoken with one VP of EHS who takes great pride in the fact that he has been to more of his companies sites than any other Manufacturing Operations executive, this has greatly enhanced the profile of EHS within the company and solidified the company’s dedication to it – it has had a galvanizing effect.