5 steps to creating a stronger EHS compliance culture
Drop the blame game, raise the bar higher for EHS compliance, and reach new levels of transparency with a process that fosters the right culture.
It’s unfortunately too easy for EHS compliance to become something of a ‘blame game’. Over the years, we’ve almost all discovered that looking only at what’s wrong is an ineffective way to get people to do what’s right. Instead of encouraging people to come forward and own (and fix) their mistakes, this approach creates an environment where employees are reluctant to report issues – and resolution ends up falling through the cracks. So, how to build an EHS compliance culture in your business?
We sat down with EHS compliance expert, Bruce Adler (founder of Adler Villani, LLC, an EHS consulting service specializing in EHS compliance issues and programs – and former EHS leader at GE for 28 years) for his view. Here are his 5 keys to success:
1. First, understand the importance of EHS compliance metrics
Pulling from his experience as Senior EHS Counsel at General Electric and more than 40 years’ experience in the EHS field, Bruce believes that there are 3 parts to a comprehensive EHS compliance program.
“There are three key elements to any successful EHS Program. The first element is knowledge. People must know what they have to do and understand the company’s expectations. The second element is metrics, the ability to clearly and consistently measure performance. The third is the most difficult – you must build a culture of compliance that reinforces the right behavior. .”
People sometimes underestimate the importance of those EHS compliance metrics. After all, how hard is it to keep track of the data? But we had a saying at GE: “You get what you measure.” You need to be collecting the right data to drive the right behavior. Metrics serve many purposes:
- Demonstrating the impact of EHS on important business outcomes.
- Enabling EHS professionals to communicate effectively with the wider business.
- Driving desired behavior among employees and managers.
It’s in the latter area where the type of metric can be particularly important.
People must understand that behavior that prevents non-compliance is more important than behavior that hides it.
2. Next, look at the metrics differently
The key to facilitating EHS compliance culture is the way you look at non-compliance itself. Bruce describes 2 types of metrics: output- and input-focused. In most fields, the most desirable metrics are output-focused, because they tell you about the results that you are achieving. However, in EHS compliance, that doesn’t follow. Output compliance metrics only tell you about what’s gone wrong. They’re also dependent on unpredictable and subjective factors.
Bruce therefore suggests that while companies need output metrics, they must also think about input metrics. These might include accident investigation rate, for example. He described one very useful metric—the ‘compliance finding closure rate’, which looks at how quickly departments acted on non-compliance findings to fix the problems.
3. Then, nurture your EHS compliance culture
Expectations and metrics take you part way towards EHS compliance. But these are just pieces of the puzzle: the third element, building a compliance culture, is harder.
Bruce provides a useful analogy:
“Let’s think about what happens when you’re driving, and you see that there’s a speed limit. Around 99% of the population will decide what speed to drive at based on two factors. One is their estimate of what is safe. The other factor is the likelihood of getting caught if they exceed the speed limit – and to be honest, for most people the second factor is the dominant consideration.
“We don’t think ‘There’s a speed limit, and therefore I should obey it’. People don’t think that way. We think, what do we think is safe and what’s the likelihood of getting caught? Neither of those contributes to the big objective, which is getting everybody to drive safely. You have to create some other reason why people will obey this speed limit, and society generally doesn’t do that.”
He suggests that while society might not do that generally, it is possible to create an expectation of compliance in an industrial, manufacturing or business setting.
“We must create a reason why people will adhere to the rules. That’s a real challenge because it’s not the way people normally behave. Companies usually need to incentivize compliant behavior. While discipline has a role, the truth is that using discipline merely promotes people to make decisions based on whether they think they will get caught.
“For example, at GE, the Vice President of EHS set an ethic that the company complied with the law. We then talked about what that really meant and explained that there were no discussions about whether the rule was difficult, or whether we were likely to get caught.
“We simply complied with the law. You must do that. You will not achieve compliance if people are assessing the likelihood of getting caught.”
4. Remember that EHS compliance can get complicated
Bruce is clear that although EHS compliance sounds simple, it’s challenging in practice. It also raises some tricky questions, especially in areas where national enforcement may be lacking.
He suggests that there are 2ways to approach this situation.
“One way is to say, yes, we understand, and if you don’t think there’s going to be enforcement, then you can ignore those laws. The other is to say, the risk of enforcement doesn’t matter, because once you start considering the risk of being caught you are undermining the principal of compliance. In the long run, if you are caught, the sanctions are going to be worse, and that could result in huge injury to our reputation. More importantly, though, you are delegating to low-level employees the ability to decide which laws to comply with and which ones to ignore. That never works out well in the long run. That’s what underlies building a compliance culture: saying the enforcement doesn’t matter, you just have to comply with the law.”
5. Leverage education and training
Your compliance culture may also need to be underpinned by a program framework, including training. Bruce suggests two forms of training are important.
“First, people must know what the rules are, and how to comply with them. That’s what we might call technical training or baseline training. The second important aspect is culture training, or training about expectations, such as that we expect you to comply with the rules as written.
“Training to build that culture is very important, and it must go up and down the chain. It’s not just about training your EHS people, you also need to train your mid-level managers. Your expectations have to be understood right from the c-suite down to the people on the factory floor.”
Keep going – and keep your focus on an EHS compliance culture
t’s all too easy for EHS compliance to fall by the wayside. Instead of focusing on why this is happening, leaders need to encourage their employees to come forward and own their mistakes rather than run away from them. The best way to do this is to take steps to foster an EHS compliance culture throughout the organization. Discover just how to do so in our insider guide webinar with Bruce – all about building your best EHS culture.