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This chapter is from the book

A Few Disclosures and Caveats

I want to emphasize that, with very few exceptions, I am not proposing a new, “game-changing,” paradigm-busting approach to managing ES&G issues. Accordingly, I do not view myself as a pioneer or visionary in advocating the approaches I detail in this book. At the same time, and viewed from another perspective, the ideas I promote cannot reasonably be dismissed as unrealistic, impractical, too expensive or time-consuming, or ineffective. Rather, my suggested approach is firmly grounded in the practices that have been developed within and by the EHS profession during the past 15 years or so. They have been deployed, refined, and demonstrated repeatedly by the many thousands of people who perform the work of EHS management on a daily basis. These people include corporate headquarters and plant/field staff, consultants, staff from some of the more solutions-oriented NGOs, and regulatory agency personnel. Collectively, they (including, in my own limited ways, myself) have brought us to where we are. Without their efforts, both the quality of human health and the environment as it exists today, and our ability to understand and effectively manage our EHS aspects in the future, would be significantly reduced.

This may seem self-evident (if not flagrantly self-congratulatory), but I believe that it is important to articulate this perspective for two major reasons. First, in keeping with my approach to writing this book (and my work more generally), I believe in transparency. This means making clear my point of view and biases so that you can reach your own conclusions about whether I am building my ideas on a strong foundation.

The second major reason is that I have observed many recent changes in the public perception of EHS issues (environment in particular), accompanied by a proliferation of media stories, new businesses and concepts, and general buzz on this topic. It seems that “green” and “greening” have again captured a significant portion of the public mindshare. While in some respects this is encouraging, and even gratifying, I believe that it is important not to let enthusiasm overwhelm sound judgment. Having worked in the environmental/EHS field for 25 years, I have seen several previous “waves” of interest in the environment. Just as in the past, I will not be surprised if the recent high tide soon begins to ebb, whether due to economic conditions or in favor of some other issue.

Moreover, while the growing interest in the environment has many positive aspects, it also has promoted a trend that I find disquieting. As I discuss in detail in Chapter 8, meaningful public sustainability (or ES&G) reporting occurs to only a limited extent and has only recently begun to grow strongly. However, there has been a veritable explosion of “green” product and service claims; new greening “experts” are appearing regularly; and scores of new companies and consortia are entering the field to provide advice and assistance on green branding, marketing, communications, and advertising. To the extent that these new entrants (both ideas and those who promote them) gain traction with the public and, more troubling, with corporate executives, there is significant risk of placing undue emphasis on the message (and/or messenger) rather than on its content. Indeed, several studies have documented that unsubstantiated or potentially misleading green claims are widespread,1 and a few particularly abusive situations have induced enforcement actions by the U.S. Federal Trade Commission (FTC). 2 Such behavior has not gone unnoticed more broadly; several recent consumer surveys indicate growing skepticism of “green” claims among the general public.3

In addition, it is an open secret that during the past decade or so, many companies have shed EHS staff, apparently in the belief that they had largely completed their work in this area, such that EHS management was now in more of an ongoing maintenance mode than a building mode. Ironically, these staff cuts were in many cases made by the same executives and companies that have most loudly proclaimed their commitments to sustainability. The consequences of this type of behavior can be seen most vividly in the 2010 BP disaster in the Gulf of Mexico, but they are playing out in less visible ways across American industry. It is only a matter of time before other “shocking” EHS incidents and accidents occur because of inadequate staffing and/or practices at firms esteemed for their solid management team, history of innovation, or even sustainability leadership.

I believe it is important to place the cart behind the horse. Indeed, in nature, and in many fields of human endeavor, form follows function. So it must be in managing ES&G issues. As discussed in Chapter 5, a sound management structure includes and is guided by corporate mission and vision and is overlain by strong governance practices. However, it also is based on the “nuts and bolts” of how EHS issues affect the business on the ground. This means that those who understand these issues, their implications, and what to do about them must be central, not peripheral, to the design, deployment, and ongoing management of the organization’s ES&G/sustainability strategy, management structure, and communications. Accordingly, I believe, for example, that a company’s highest-ranking sustainability executive (such as the Chief Sustainability Officer or Senior Vice President for Sustainability) should not be a public relations, marketing, communications, or investor relations professional unless there is a compelling reason for such a selection (such as earlier career experience in EHS). Nor should the sustainability (or ES&G) function be housed in or report to any of these communications-related functions.

Instead, in the context of managing for ES&G improvement or sustainability, it is critically important for organizations and those responsible for managing them to emphasize accomplishment over accolades, competence over appearances, and fundamentals over capturing favorable publicity. It starts with getting (or keeping) one’s house in order. You do this by maintaining a high and improving performance level along two basic dimensions that have been with us since the dawn of the EHS field as a defined profession 40 years ago:

  • Complying with the law and all applicable regulatory requirements
  • Adequately protecting the health and safety of one’s own employees

I would hope that you agree that these two conditions reflect the minimum EHS performance level that you would expect from any well-run organization. I would go further and suggest that any company or other organization that has not yet achieved (or that has retreated from) a high and improving level of performance along these two dimensions should dispense with any notions of, or plans to actively pursue (or, more troubling, tout their own), sustainability. Instead, the executives managing such organizations should either get back to basics or institute appropriate programs, depending on their situation, to build the required capability.

Irrespective of a particular organization’s current posture or aspirations regarding sustainability, I believe that the principles and approaches outlined in this book will be of material value in helping EHS and sustainability practitioners (both internal and external to the organization) and other members of the organization. Whatever business function they perform, they will understand where they are, what they should focus on, what structures and practices will help them manage the important issues, and how they should measure and report their performance over time. I also speak to some of the important professional skills and personal attributes that will increasingly be required to achieve success in positioning your organization to achieve sustainable business success.

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