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A monthly column on strategic EH&S management, sustainability and Responsible Care Management Systems by experts who have spent time in both the trenches and the boardrooms.
Steve: That's an interesting twist to a rather common question on how to conduct benchmarking. The short answer is, ‘you can't' – it's an incomparable situation, e.g. ‘apples and oranges'. Thus, you will need to seek out comparable peer companies and business units, and benchmark measures and performance with them. Then, set your goals, monitor your performance, and revisit your measures/goals to ensure their appropriateness (e.g. PDCA). If performance measures are significantly out of line with your company's other business units (positively or negatively), insert footnotes explaining why.
In speaking with the reader, the business is highly competitive and their peer businesses are either small, regional independent firms or specialty units within larger, integrated companies. Therefore, while many benchmarking efforts are conducted by telephone or email surveys, those methods don't seem appropriate as they're unlikely to provide useful, accurate data in this situation.
There are two other approaches:
If the issue is sensitive and you don't want the other companies to know about the effort, then it's truly 'competitive intelligence' and would have to be done by reviewing each site's public environmental files – either comparable stand-alone facilities (integrated or independent) or portions within larger facilities. Difficult, relatively expensive and maybe not precise, but doable.
If the issue isn't sensitive and other companies might even want to participate, then it's more akin to benchmarking. The best and most accurate way to do this is to convene a 1-day benchmarking event (facilitated by an independent, third-party at a ‘neutral' site) with invitees that would share a common purpose, known in advance so that they could prepare and bring their contributions to the table and be participants, not merely 'takers'. It would be important to a) have an antitrust statement/notice distributed ahead of time and repeated at the beginning of the meeting and b) present/discuss normalized data, but with a few key associated parameters to help put the results into perspective. Results would be provided as ‘company A', ‘company B', etc., with only each company knowing their respective company's designation.
The second technique has the clear advantages of more meaningful data and quicker results at less cost (particularly if all participants share in both the results and the costs) – unless secrecy is tantamount.
A question back to our readers - Do any of you have suggestions on how to handle the situation where the submitter's company lawyers, due to the nature of the specific marketplace and companies involved, are expected to be reluctant to engage in peer-to-peer benchmarking discussions, despite an antitrust statement? Let us know! Readers' helpful suggestions will be listed in next month's column!
As an independent, contract management systems auditor , am I prevented from providing other EHS consulting services to companies and sites for whom I conduct RCMS or RC14001 audits through an Audit Service Provider (ASP)?
Steve: Contrary to popular belief, Specification RC204.03, requirement 4.1.4, does not prevent ASPs from providing consulting or training services, only that such services must be independent and that the ASP shall a) ensure no clients are given the impression that use of those services would bring advantages to the client, b) say nothing to suggest audits would be simpler, easier or less expensive, and c) not market such services together with the audit. From a practical standpoint, ASPs avoid any potential problems by simply not providing management system consulting or training services.
There are no such requirements in RC205.03, Auditor Qualifications. BEAC's certification (and I presume RABQSA) incorporates the organization's Performance Practice on independence (I.B.2.E) that requires “persons… should not be assigned to those audit activities they previously performed until a reasonable period of time has elapsed.” You should be okay so long as you, as an independent auditor, draw the line at auditing those companies or sites to whom you have provided RCMS or management system consulting/training. Be aware, though, that individual ASPs may have their own, much stricter requirements.
To restrict yourself from providing any consulting services to companies for which you conduct Responsible Care audits could severely limit your future business opportunities, especially if you primarily focus on providing service to the chemical industry.
Postscripts: The Death of Environmentalism. Much has been written both pro and con about the essay, “The Death of Environmentalism” by Michael Shellenberger and Ted Nordhaus , wherein the authors opine that environmental activism in the U.S. (and the organizations that spearhead that activism) is not equipped to handle today's more complex, global environmental issues, lacks an expansive, value-based vision and other reasons. The authors then go on to offer their ideas for a solution. Joel Makower's blog provides a good summary and his thoughts on the matter.
In the months since the essay's publication, I've been reading various commentaries, blogs and op-ed pieces about it so as to develop my own thoughts. Overall, I think that the authors have it right, but not for the reasons most others except Joel have offered.
First, the essay dares to say 1) “It's not working as well as it did, or can.” 2) “Here's the evidence we offer to support that opinion.” and 3) “Here's our concept of a solution.” It's one of the first major (or at least well publicized) treatises that calls for challenging the norm through the balanced discussion and global-oriented participation that the March ‘Postscripts' and our other commentaries have called for in the past.
Second, it dares to open honest dialogue about the main underlying issue – that times and issues have changed. They've become more complex by becoming less local and episodic (e.g. think Kanawha Valley , Love Canal , Chemical Control, etc.) and more global and chronic (e.g. think ozone layer, water availability, climate change, etc.). They've also become less personal and immediate, e.g. transformed from ‘that's affecting me now' to ‘that could affect someone like me, somewhere, sometime in the future'. Therefore, just like any government, business, product or advertising campaign, the approaches and tactics used in the past are no longer effective.
While we can't say for sure that environmentalism is dead, its current methodology has aged and is in need of at least an extreme makeover if not a total reinvention.
|Steve Rice (973-966-5505) is president of Environmental Opportunities, Inc., a strategic EH&S management and project support services company in Florham Park, New Jersey. He has 30 years of executive EH&S leadership experience, including 25 years with both Exxon and BASF, and is an ACC- authorized Responsible Care Management Systems (RCMS) auditor.|
Copyright 2005, Environmental Opportunities, Inc.