I don’t know about you, but it seems to me that since the beginning of the economic downturn, there has been a steady drum beat in most large companies that the only thing the company needs to worry about from an environment, health and safety (EHS)  perspective is compliance.  This inevitably prompts at least two follow-on actions.  The first is that it’s okay, in fact it’s more than okay, it’s imperative that companies fight any potential new legislation.  This means that we work with lawyers, trade associations and government affairs to do what it takes to prevent legislation.  The second is that companies fight existing legislation because it is seen as costly, burdensome, unnecessary and otherwise preventing business from flourishing.   Once again, we pull in our legal teams and we comb the regulations looking for a way around those problems that pop up, and if we can’t find anything, we develop as air tight a case as possible to plead before the regulators about why this particular event is an anomaly.  All other activities, such as proactive work to avoid running afoul of legislation are seen as being ivory tower, “nice-to-haves” and otherwise wasteful of limited resources.

It reminds me of the sign I’ve seen posted among the desks and cubicles of places I’ve worked, “Why is it that there’s always enough money to fix the problem but never enough to prevent it in the first place?”   I think one answer is that EHS folks like to be seen as the heroes, the white knights, the defenders of the defenseless victims of regulatory excess.   I think you know what I mean.  An event occurs, we get a frantic call, we search for someone to blame as we come riding in with our tall white hat on our silver steed (well, our mega-SUV) and solve the problem, put out the fire, put a lid on it.  It gets the adrenaline rushing, we get the kudos, and we assure ourselves “it could have been worse.”  Never mind that it could have been avoided, we just won’t talk about it.  Besides, it’s okay to pay lawyers millions of dollars to fix the problem with the regulators or in the courts.  That is real value added.

I am not quite sure what it is about humans that we like to take risks and see if we can get away with it.  There is a certain thrill in knowing that we did something we weren’t supposed to do, and we got away with it.  The kind of behavior we encounter when managing EHS in a company is not a lot different, I think, than the thrill investment bankers got in taking a tenuous financial position and then betting against it.  In some cases, they got away with it and reaped millions of dollars in profit.  In the final analysis, they delivered a severe recession and a worldwide debt crisis.  It’s just a matter of scale and a different domain, but it’s still the same craving to take a risk, not get caught and walk away with a tangible or intangible reward.  Nothing ventured, nothing gained, right?

As you might have guessed, I’ve never quite understood those members of the EHS community who thrive on fire-fighting.  It’s not that I don’t like to get an adrenaline rush, I just get them in other ways.  You might say that I swallowed the poison and tend to be on the side of folks like Ben Franklin who opined: “An ounce of prevention is worth a pound of cure.”   It has always struck me as odd that prevention is broadly seen as being expensive, unnecessary, or as gold plating.  It is true that prevention processes provide less of an immediate thrill, and progress is measured through the accomplishments of other people making many small decisions over time.  That means I don’t get a lot of credit for what I as an EHS leader might do since someone in R&D or manufacturing is likely to get the credit.   Moreover, to senior leaders, my contribution is likely to be invisible since it will be built into a business process that I am poking and prodding to keep running, but if all is working as it should, will very likely prevent one kind of adverse event or another. 

Another thing about prevention is that you have to accept that if there is gratification to be had, it will be a long time in coming.  And, as folks like Malcolm Gladwell and others have popularly reported, humans on average are not very good at delayed gratification.  The experiments went something like this.  Put a marshmallow in front of a small child and tell that child that if they don’t eat the marshmallow for 20 minutes, they can have two or more if they wait.  The results?  Some children are better at delayed gratification and are perfectly content to wait it out; most are not.  For a society that has been weaned on instant gratification, delayed gratification is a hard sell. 

Prevention is also something that is hard to measure.  Correlations of no fines or major adverse events with the implementation of one program or another does not necessarily mean that you can attribute causality.   It may be blind luck, a combination of factors, or what might loosely be called the culture of the company.  Take for example energy conservation.  At most companies, you hear a lot about energy efficiency – swap out that motor with a more efficient one, change the lighting to T5 fluorescents or LED’s, replace the 3-year-old server with a more energy-efficient one.  But how often do you hear about energy conservation, the idea that you just don’t turn something on until you need it, as the flagship energy program?  Conservation, like prevention, is a lot about not doing something in the first place, and not doing something we’re accustomed to doing (i.e., a habit) requires a certain presence of mind and a bit of planning. 

The last thing I’d say is that to implement successful proactive programs requires a different set of skills than say, for example, accident investigation, or auditing, or environmental regulatory affairs.  It has been my experience that very few possess the required skills and those that do are generally not greatly valued in EHS organizations.  It gets back to being a systems thinker, someone who can think intuitively and imagine different future scenarios, someone who can delay gratification and doesn’t need a lot of “attaboys” along the way.  And that kind of person is a rarity.

I’ve only begun to explore this and will come back to it another time.  In the meantime, let me know what you think.