Tag Archives: EHS management

The problem about data

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Maybe it’s because I’m a scientist, or maybe it’s a personality preference, but I’ve always been intrigued by people who seem content to make decisions on the basis of a relationship, or on what some celebrity, business leader or political leader says.  My reaction in those cases is to become more skeptical, investigative, and analytical which in turn usually prompts me to discount what is being asserted as a truth or a direction I should head.  Throughout my career I have always believed that I need to collect enough objective, verifiable, multi-characteristic data upon which to base a program, project or business decision. 

When it comes to sustainability, environment, safety, health, green chemistry and engineering, and related fields, it has always troubled me that professionals and practitioners in industry and government will spend more time talking about needing data and not having data than they spend collecting it.  After talking about it ad nauseam, many seem to ignore the fact that despite not having enough data, they’ll go ahead and make decisions anyway.  Let me give a specific example.  In sustainability circles, it is now in vogue to want a life cycle assessment for a product, a building or a service.  I will be the first to admit that doing a life cycle assessment is not easy and it does require a lot of data that in many cases is still not easy to get.  There are approaches one can take around this lack of data, but the general approach is to start cutting things out of the life cycle assessment.  So, the boundary conditions will be narrowed to gate-to-gate, or raw materials to factory gate, or perhaps gate-to-end-of-life.   Or, my perennial favorite is to focus only on a single impact category, usually carbon, carbon footprinting, or eco-footprinting, to the exclusion of every other impact category.  Or, they’ll focus on a single endpoint and trumpet that as the biggest issue one needs to pay attention to.  Doing these things is better than doing nothing at all, right?

Well, maybe, but arguably not by much.  Not to pick on anyone in particular, but to make this more tangible, let’s choose another example.  And please, don’t misunderstand what I am about to say because I do believe that what some companies are doing is profound and is setting the agenda for an industry.  These companies are to be applauded for their work.  Nevertheless, I was looking at the Sustainable Apparel Coalition (SAC) web site yesterday, although I could have chosen any other sustainability-related coalition of your choice.  They all do this.  Anyway, they are attempting to develop a multi-criteria decision-making framework for determining the sustainability of apparel.   They call it the Higgs Index.  The Higgs Index, according to the web site, is largely based on the Nike Materials Sustainability Index (MSI) and the Eco Index, a product of the Outdoor Industry Association.   If you look at the details of the MSI, you will see that Nike punts on certain parts of the life cycle data and on the green chemistry data.  In the case of the LCA data, it doesn’t exist, so they use proxy data, professional judgment and order-of-magnitude estimates – all of which may be acceptable workarounds if done correctly.  In the case of green chemistry, they don’t believe there is a standard method to evaluate it, so they give it a very low weighting.  I don’t happen to agree with that assessment, but that’s another story.

At least Nike, and a few other companies in different industries, are attempting to do something that attempts to be objective and multivariate.  And, to their credit, they are making the process transparent.  What bothers me is that most other companies are not investing to the same extent to develop a process, collect data, or doing too much of anything else.  You could say that is the cost of leadership and the price to set the standard against which all other companies are measured.   The thing that really angers me, though, is the expectation that all the underlying data, if it is developed, should be given away for free.  I have seen this played out time and again.  One company spends a considerable amount of time, energy and effort to develop data and a process for evaluating “greenness” or a product life cycle, or product sustainability only to have tremendous pressure to make these fundamental data public.   You could argue it is a trust issue and people believe they can’t trust data unless it is transparent.  I think it is more that people are unwilling to do the work and want something for nothing.

Today I was reading about how recruiters are using big data and data analytics to zero in on potential candidates.  Big data is what allows online marketers to zero in on your preferences for something by virtue of your on-line profile and data integration from multiple sources.  It’s also being used by both presidential campaigns.  So, you’re on Facebook or some other site and up pops an advertisement for a book, a pair of shoes or something else that is exactly what you didn’t know you wanted, but which piques your interest because it is similar to something you’ve purchased before.  It helps recruiters find preferred candidates (at least those with the biggest online presence) and it helps presidential candidates zero in on certain voters representing the most likely to be influenced with a targeted pitch.  How much pressure is there to make the data that the large search engine companies, all these market analytics companies and the campaigns collect publicly available for free? 

In the final analysis, I think it points to a truism that when it comes to the environment, it’s all free.  The problem, of course, is that when it’s free, it isn’t valued very highly and that certainly explains a lot, doesn’t it?

As always, let me know what you think.

They’re the experts…

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As a chemist who has spent a majority of my career working in environment, safety and health roles, I am frequently confronted by the reactions of many R&D chemists, particularly those in academia and government laboratories, towards laboratory safety.   It’s not that the attitude in industry is all that different, it’s only a matter of degree.  For the most part, R&D chemists are either completely ignorant of chemical safety, or they studiously ignore it.  The rhetoric goes something like this; “Oh, you don’t understand, and besides, you have to be practical, David, or else chemists won’t listen to your warnings at all.  We only handle small quantities of many chemicals, so the risk just isn’t there.  Besides, we handle so many different chemicals it becomes unwieldy and we can’t afford to be bogged down by safety and have it interfere with the good science we’re doing.”   Or, alternatively, from some safety colleagues in R&D settings: “they’re the experts with chemicals and chemistry, of course they’ll be safe.”

Really?  Tell that to the family of Sheri Sangji, the young UCLA graduate student who in late 2008 was handling t-butyl lithium when the tubing on a syringe she was using became disconnected and as the butyl lithium caught fire, she knocked over a bottle of hexane.  She died 18 days later of complications related to her burns.   It’s good that the UCLA Board of Trustees accepted responsibility and it is most unfortunate that the young faculty adviser is still facing criminal charges.  And thankfully, some good has come of this as some in academia slowly gear up to improve safety programs.  Just today, Chemical and Engineering News reported on a joint initiative between three universities and DOW to improve academic laboratory safety.  It’s taken 3 years, and it is only a baby step, but it is a step in the right direction.  We’ll see how much staying power it has.  My experience tells me that it is likely that we’re a ways from institutionalizing an appreciation for safety in R&D laboratories.

So let’s take a closer look at these pernicious attitudes towards safety.  It is true that R&D chemists may handle a large number of different chemicals and many of these chemicals are just plain hazardous.  And, I take the point that hazard is not the same as risk and that it is possible to work safely with hazardous materials.  Many people do that every day.  It’s also true, as I have pointed out earlier, that chemists like to use hazardous, reactive chemicals precisely because they are so reactive.  Their extreme reactivity ensures they react reliably and completely, and from a chemist’s perspective that is a desirable thing.  That’s just the nature of the work, right?  I would say that is the case, only because it is what chemists have done for the past 150+ years.  They refined, extracted, heated, boiled, triturated, and whatever else they did because those were the tools they developed.  Imagine if all of life adopted these approaches to make the various chemicals they need to sustain life.  It would be a very different world.  It also begs the question as to why we keep using the same old ways to make what we make?  Quite simply, it’s the easy way out.

One strategy is to use different chemicals and chemistries to avoid the need for using hazardous compounds.  Saying that brings us to the second objection: doing something different is impractical, it’s more expensive and it interferes with all the good science we’re doing.  It may be impractical only because it’s different, we don’t know how to do it any other way, and we’re unwilling to invest money into finding an alternative.  However, it’s not interfering with good science; there’s more than enough good science to be discovered by taking a different, safer approach.  Yes, it is different, we have to operate under different constraints, and until we invent other tools to do our synthesis, it may take a little longer.

Finally, let’s toy with the notion that chemists know more about chemical safety than the average safety person because they’re experts in chemistry.  The first time an EHS colleague said this I was shocked into silence; I couldn’t believe they actually thought that, and assumed it wasn’t really what they believed.  I was wrong and they did think that, and everything in my experience before and since has only underlined the fact that many chemists are either mindless about chemical safety or they studiously ignore it, or they gamble with the risk because they are confident they can accept the risk and not get caught.  It’s time that chemists, especially academic chemists, take laboratory safety more seriously.  It doesn’t take more time if it is built into the culture and the experimental design, it isn’t more expensive, and we simply can’t afford to have more incidents like the one that happened at UCLA.

As always, let me know what you think.

What to Report?

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Anyone in a large international company tasked with reporting on environmental, safety, health, sustainability, corporate responsibility, or whatever other related performance you might be reporting on, knows just how difficult this can be.  While it is true that more companies are reporting, the increased visibility doesn’t mean more resources are being allocated to do it that the task has gotten any easier.  In general, top executives want the kudos and the good public reputation that comes with consistent reporting and high-ranking by any of the dozen or more active rating organizations that have sprung up over the past decade.  While I think some people collecting these data and putting it into a coherent report see the possibilities to use company performance to spur action and innovation within companies, these people are generally not respected or appreciated, and the data is not capitalized upon by executive leadership.  Reporting is seen as a communications exercise and the underlying data is not used to change business practices.

I was interested to see a recent post by Kate Schrank of Sustainability Partners on the Global Reporting Initiative’s (GRI) G4 initiative.  I thought the post summed up what many in industry have said since the inception of CERES and the implementation of the first iterations of the GRI – “Don’t ask for Too Much at Once.”  I remember attending an early GRI summit in the late 1990’s with a colleague from DuPont where we were one of a very few industrial representatives in a sea of NGO’s, independent parties, and governmental or international agencies.   My impressions then were pretty much what Kate has found by polling companies about the G4 Initiative.  From an industrial perspective, my perception has always been that people who don’t work in industry absolutely don’t trust industry.  So the philosophy is that if industry can be forced into reporting on a whole range of business practices, then the trust level will increase.  The interesting thing to me is that despite more widespread and more comprehensive sustainability reporting, I don’t see that trust is increasing.  But, I do see that the pressure to report more and more is increasing.

Having said that, I don’t see the lack of trust changing all that much, no matter how much is reported, how comprehensively data is reported and how much of the reporting is validated by “independent” third parties.  Let’s take the case of financial reporting as an analogy.  Despite a tremendous amount of detailed financial accounting and reporting, despite auditing of these data by “independent” third parties, and despite all the rules and regulations (e.g., Sarbanes-Oxley), we still had Enron (pre-S-O), we still had the major real estate junk bond scandal that led to the current recession and worldwide debt crisis (post-S-O.) and we continue to have revelations that some banks and investment firms are playing fast and loose with other people’s money leading to the loss of 2, no 4, no…billion dollars. 

It’s also interesting on another level, for as complex as financial reporting has become, reporting through the supply chain is infinitely more complex.  I don’t think people working outside of procurement functions generally appreciate the complexity of supply chains, but it is not unusual for some companies to have tens of thousands of first-tier suppliers.  Think about that for a moment.  It is difficult enough in large companies to negotiate consistent pricing (say for fasteners, or office paper, or computers) from a single supplier or maybe two or three suppliers, across multiple internal lines of businesses, geographic locations, etc.   And the desire is to have detailed, comprehensive, contextual reporting on a range of sustainability issues.   As Kate pointed out, the struggle to comply with the Dodd-Frank act and the requirement to report on conflict minerals has proven to be a monumental task, and that’s just one issue of many.

My position is that companies need to report on what is material to the company, and frankly, not everything that people outside of a particular company may want to have reported is material to that company.  I also think that most companies do not understand what is truly material to their sustainability, and I’ve written about that in earlier posts.  I also know that a majority of people do not understand risk and get caught up dwelling obsessively on hazard when that is not terribly helpful.  To the extent that reporting can help make visible the true sustainablity risks and opportunities, I think it is a useful and important undertaking.  Unfortunately, we have a way to go before this is the case.

As always, let me know what you think.

Keeping Score

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During the Chicago teacher’s strike that dramatically played out before us in early September I was reminded of a dilemma facing anyone who has spent time in Corporate EHS organization over the past 20 years.  In the case of U.S. public school teachers, there is a general complaint that they have to teach students to take a test, not using a test to measure the quality and extent of the education the child receives over time.  This leads, so the argument goes, to students with mastery over taking tests and not having mastery over a subject.  It’s an interesting argument and one that evokes considerable passion among parents, teachers, school administrators, school boards, and government entities at all levels.

The public school debates are similar to debates anyone in the EHS organization of a large company at a corporate level is used to having.  Senior leaders of all stripes and persuasions are generally pretty competitive people.  They like to have goals, targets and measures in all parts of the business.  A former CEO of one company I worked for said that “if you’re not keeping score, you’re only practicing.”  Alternatively, the mantra is “if you aren’t measuring, you aren’t managing.”  On the business side you have sales goals, earnings before interest and taxes, (EBIT), earned value added, ROI, and on, and on it goes. 

It became common practice in the early to mid-90’s to begin reporting on company EHS performance and so we saw such measures as emissions to air and water, hazardous and non-hazardous waste, toxics, etc., etc., while in safety we had some variation of lost time injury and illness, day away case rate, days away, fatalities, etc.  By the mid- to late-1990’s, it became fashionable to establish reduction goals for a few key measures and we saw individual companies establish different types of goals.  Everywhere there was considerable pressure in those companies who set goals to meet or exceed those goals.

For those outside of Corporate life, I suspect that if you were someone who noticed and cared, there may have been a certain sense of relief or comfort in knowing that companies were taking steps to measure EHS performance and make this performance transparent.  As a veteran of Corporate life, I will tell you that establishing EHS goals, tracking progress and reporting that progress is anything but easy, and I have the scars to prove it.  

While working at companies that did this, and having been intimately involved in thinking about, establishing, internally vetting, gaining approval for and tracking goals, I can confirm that it makes anyone who does this a very unpopular person.  Ironically, perhaps, EHS colleagues in the business areas are among the most difficult to convince, coax, and cajole to accept goals since they are invariably seen by the business, incorrectly I might add, as the ones who must deliver on the goals.  Let me be clear – it is the business that is responsible to deliver on the goals, not the EHS person’s responsibility. 

Having said that, here’s how it plays out.  In the first place, we don’t need goals, so our EHS colleagues say, because the business knows its business, you don’t, and they’re doing just fine, thank you very much.  Okay, so let’s say you’re a masochist and you think the company needs goals to challenge it, so you move forward, despite being the object of dislike by your EHS brethren.  Once you spend two years or longer negotiating a goal or goals, then selling it up and down the line until the CEO and/or Board signs off on the goals, the business has to begin to report on their progress. 

This involves an almost endless amount of chasing up one facility or another who, for one reason or another, fails to report.  Once they do report, our hapless metrics collector will collate the data and report out the progress.  That’s the second time everything hits the fan.  Obviously the data is wrong, the process to collect the data is wrong, and how could you be so stupid as to not see that it is wrong.  So, you spend large quantities of time tracking down all the mistakes in entry, the transposition errors, the wandering decimal places, or whatever else turns out to be the problem.  Eventually, the business agrees the number(s) is (are) correct, so now the goal is obviously the most stupid goal in the world and the only thing that is more stupid is the person who worked to establish the goal in the first place.   Said person obviously does not understand the goal, the business, or reality.  I won’t even go to the next step which is validating the data through a third-party since you probably can imagine where that will go.

Stepping away from the internecine strife and accepting that as a fact of life, corporate EHS or sustainability goals really do develop a life of their own.  And here is how chasing corporate goals is like teachers in public schools chasing better average test scores for their students.  People begin to manage to the goal, not to the overall “spirit” or intent of the goal – to improve performance, enhance the business, aspire to leave people and the planet better off.  This managing performance to a goal cuts both ways. 

If the business achieves the goal too easily, then the goal was obviously right and the company doesn’t really need to do anything more to improve, even if performance, when benchmarked against peers, may not be where it needs to be.  Alternatively, if the goal is not achieved, it is too idealistic, impossible to meet, the business reality is not understood, and EHS folks are obviously not doing their jobs.  This rationale, incidentally, buys the business a “get out of jail free” card and excuses them from trying to make progress against the goal. 

As in public schools, there are those students who actually do learn, flourish, and go on to bigger and better things.  Likewise, many companies do establish goals, meet them and are likely to be more sustainable as a result.  We just have to try to remember that goals do have benefits and can help to move companies towards being less “bad.”  But as many have pointed out, being less “bad” may be a good thing, but it isn’t likely to be sustainable.

As always, let me know what you think.