As we move into 2017 there is a lot of uncertainty. The new President of the United States will introduce many changes, some of which may directly impact the world of EHS in the U.S. and overseas. I have been tasked with forecasting where auditing will go in 2017 and as I think about the path auditing will move along, I keep coming back to the same theme. Just one word really. Culture.
The word culture can mean and refer to many things. The same is true with regard to the use of the word culture in relation to EHS. It can relate to the culture of a jurisdiction where a facility is located, leading to certain rules and enforcement practices. It can lead to certain attitudes and methods of management implementation. It can also refer to how a company prioritizes certain issues to mitigate risk.
According to Merriam-Webster, there are actually six definitions of culture. I’m only concerned with one definition, however: the set of shared attitudes, values, goals and practices that characterizes an institution or organization, what we often term “corporate culture”. In the auditing world, when we discuss corporate culture, we often throw around terms like “safety culture” and “compliance culture”, but what exactly do these terms mean and more importantly, how do we audit them?
I was recently at a conference where one of the presenters was discussing the value of audits. He spoke about how audits can identify compliance gaps and help corporate prioritize and mitigate risks. I agree, audits can do those things, but I think audits can do so much more. As companies age and their processes become more mature, so too must their audit programs which should look beyond mere compliance with the applicable requirements. Instead, audit departments need to consider the facility and oftentimes the company as a whole as opposed to looking at individual programs. In an age where every incident and exceedance is public information, it is more important than ever for companies to go beyond compliance to a true understanding and prioritization of the applicable requirements and their importance in maintaining a safe and environmentally-friendly site. This is the future of auditing.
As companies age and their processes become more mature, so too must their audit programs grow and look beyond mere compliance with the applicable requirements.
It is easy to say that we need to start looking beyond compliance in our audits, but how exactly do we do this? It isn’t an easy question to answer and I don’t think that every company has the resources and capability to do it. As our audit clients grow their audit programs, many of them are moving past compliance audits of their manufacturing facilities and are starting to look at their other risk profiles, including offices and warehousing. Some are even beginning to look at their supply chains. I think this is an important first step in auditing company culture. An injury or release can happen at any facility, not just those with the highest risks. It is important to make sure that lower-risk sites are also aware of their environmental and occupational health and safety responsibilities.
The second step to auditing culture is to use the results of a compliance audit to determine specific topics or areas that warrant a deeper dive. Once a baseline audit has been completed, several of our clients are using the results to choose areas that need further review, such as the implementation of high-hazard programs like lockout/tagout (LO/TO) and confined space entry, or Title V air permits in the U.S. These companies already have a determination of compliance, what they are looking for is a true understanding of the requirements and how to meet them. These are the companies that are incorporating EHS into their corporate culture and showing that compliance is important.
The third and, for now, final step for auditing culture is to really listen to what employees are saying when we speak with them. We all view interviews as an integral part of our audits but how often do we check out after hearing the answer we were looking for and move on to the next topic. In my experience, people usually like to talk about themselves and they usually reveal quite a bit about the site and even company culture as they become more comfortable.
In a similar vein, I believe people usually want to do the right thing. An employee doesn’t remove the guard on a piece of machinery because they want to get injured. A worker doesn’t leave the lid on a container of waste bulbs open because they want to contaminate the soil. They do it because they have not been properly trained, because there are unreasonable expectations and because they do not truly understand the reason behind requirements and the implications of non-compliance. By simply listening to the people in the plants, the offices and the warehouses, we can learn a lot about how a company functions.
We’ve just discussed the basics of auditing culture, but what do we do with all of the information we gather? The same thing we do during every audit…we analyze. Like any other audit, we must put all the pieces together and look at the big picture. We must determine what our results reveal about the company’s attitude towards compliance and we must use our results to help corporate revise their priorities and weave EHS compliance into the everyday operations of the company.