 |
ES&H Management System Verification (MSV) Tool
|
The MSV process developed by ACC is a tool (not a requirement) that DOE sites may consider to help determine
whether their ES&H program is truly integrated into all work at all
levels by all employees. The use of the process is strictly voluntary
and at the discretion of the DOE sites who, if they decide to use
this process, may use it: 1) informally and internally without peers
from other sites or community representatives; in which case, it would
a form of self-assessment; or, 2) formally with external involvement
including peers and community reps.
Background
In 1993 the American Chemistry Council (ACC) Board of
Directors recommended a process be developed to verify the management
system of their Responsible Care® program. The Board stated that this
verification process would assist ACC companies in improving their
ES&H performance and contribute to the building of trust between chemical
facilities and their neighboring communities. After three years of
development and testing, ACC companies began using the process in
1996, and more than three dozen companies have now completed the Management
System Verification (MSV) process. Although the results are given
only to the company, many companies have publicized their results.
For example, the Rohm and Haas Company has their MSV report on the
Internet at http://www.rohmhaas.com/company.dir/MSV.
Description
The MSV process:
- verifies that appropriate systems are in place and functioning
to assure continued compliance with applicable regulations;
- verifies that appropriate ES&H performance goals have been established;
- looks for internal company audit procedures to verify ongoing
compliance with company goals and external regulations;
- is NOT an audit to identify non-compliance with local, state,
or federal regulations;
- does NOT validate the adequacy of ES&H performance such as the
level of air or water emissions at a facility.
The ACC MSV process is built around
a verification protocol, or guidance document, which organizes the
verification into a general sequence of steps. The protocol identifies
organizational structures, responsibilities, practices, procedures,
processes and resources for implementing and maintaining a management
system which are then reviewed by a team of verifiers. In the ACC
process, industry peers accompanied by community representatives,
engage in a series of open-ended interviews of company personnel,
documentation reviews, and on-site observations to determine whether
a company has appropriate, functioning, and sustainable management
systems in place. Through this interview/review/observation process,
the industry peers and community reps are able to identify strengths
and areas for improvement in the company's management systems. These
findings are submitted to the company being verified (and ONLY to
the company being verified) in a final written report.
The protocol organizes the verification into a general sequence
of steps covering five core areas:
- Policy and Leadership;
- Planning;
- Implementation, Operation, and Accountability;
- Performance Measurement and Corrective
Action; and
- Management Review and Reporting.
These core areas are essentially the five major steps in a Work
Management System used for all work including ES&H as an integral
part.
"Attributes" have been identified within
each of the five core areas. Attributes are the necessary systems,
organization, policies, programs, etc. that support each core area
of the management system and are the basis for the evaluation of the
overall management system. Evidence of the existence of these attributes
and their integration into the company's operations and culture should
result in effective management systems. Sample interview questions
have been developed to determine the existence and integration of
the attributes.
MANAGEMENT SYSTEMS VERIFICATION PROCESS STEPS
A procedure for carrying out a management systems verification could
include the following steps:
- Site contractor Executive Contact
volunteers for a management systems verification by notifying
the DOE, EH-53, Office of Field Support.
- Verification team leader and members
are selected from a pool of trained individuals.
- Supporting ES&H contractor identified.
- The team leader (with support of
the identified contractor) contacts site contractor's ES&H Manager
requesting information about the company and supporting documentation
(define info and docs).
- Team Leader (with the support of
the identified contractor) and the site contractor's ES&H Manager
will determine the scope and conduct of the verification, review
the list of individuals to be interviewed, and determine which
facilities will be visited by the team. Upon request, the site
contractor will provide to the team names of appropriate second-and
third-party contacts (carriers, distributors, subcontractors,
community representatives) for possible interviews.
- A site contractor/verifier legal
agreement covering protection of confidential business information
and indemnification of the participants is signed.
- Site contractor identifies appropriate
public representatives who will accompany the verification team
on its visit. These individuals are selected by the site contractor
through its local dialogue process.
- The team leader will contact the
public representatives to ensure that they are aware of their
selection and understand the verification process. DOE, EH-53
will provide the company with a verification orientation kit for
distribution to each community participant.
- The verification begins with the
team's visit to the site contractor's headquarters to interview
the executive contact and senior staff
- Team visits selected facilities/operations
to interview manager and appropriate staff. During the site visit,
the team conducts a plant tour.
- Team conducts closing meeting with
ES&H Manager and/or appropriate staff at each level of the process.
- The team develops its final narrative
report. A draft of the report is sent to the site contractor and
area office factual review. Only the site contractor and area
office receives a copy of the final report.
- Each team member will certify that
all work papers and related information are collected and destroyed.
All documents supplied to the team will be returned to the site
contractor.
- DOE HQ issues recognition of participation
to company.
MANAGEMENT SYSTEMS VERIFICATION
Protocol
Management Systems Verification is designed
to support an organization's efforts to improve their responsible
management of DOE facilities. The core elements of the Management
System are defined below and are shown in the following figure of
an Integrated Work and ES&H Management System. The core elements
and their Attributes and Verifier Questions are subsequently described.
Policy and Leadership
This management element addresses the
leadership exhibited by senior management in setting clear policy
and guidelines for performance, and for enhancing the value of the
ES&H ethic within the organization.
Planning
This management element addresses; 1) the identification and assessment
of relevant regulations and industry standards, 2) the evaluation
of product, process and distribution risks, 3) the identification
and assessment of employee and community concerns about the organization's
environmental, health and safety performance, and 4) setting priorities
and goals for performance improvement.
Implementation, Operation, and Accountability
This management element addresses the
achievement of objectives and policy expectations. It also covers
the preparation and competence of employees to carry out their tasks,
and documentation that is critical to the execution of those tasks.
Performance Measurement and Corrective Action
This management element deals with the use of performance indicators,
performance reviews, accident and incident investigation, compliance
audits, data records, and taking or recommending corrective actions.
Management Review and Reporting
This management element addresses the
manner in which the organization reports its performance to its
stakeholders and senior management, and how the organization and
senior management reviews that performance relative to goals and
makes appropriate changes in goals, policies or priorities.
The Department of Energy and its contractors are committed to support
a continuing effort to improve the responsible management of DOE
facilities. They pledge to manage their operations accordingly,
placing a high priority on the protection of the environment, and
health and safety of their employees and the public, and the implementation
of sound ES&H management practices. To do so effectively their environmental,
health and safety activities must be conducted within a structured
system that is integrated with their overall management activity.
The core elements of a ES&H management system are described below:
CORE ELEMENTS OF ES&H MANAGEMENT
SYSTEM
- POLICY AND LEADERSHIP
This management element addresses the leadership exhibited
by senior management in setting clear policy and guidelines for
performance, and for enhancing the value of the ES&H ethic within
the organization.
Attributes
Senior management demonstrates leadership and commitment for their
organization (company, plant or business unit) by active participation
in the creation and implementation of a clear and visible policy
that:
- » is relevant to the nature and scale of the organization's
products and processes,
- » fosters openness in dealing with stakeholders and takes
into account public and employee inputs,
- » includes a commitment to continual improvement of the management of ES&H and sets a framework for reviewing and establishing
ES&H objectives and targets,
- » includes a commitment to comply with relevant legislation
and regulations,
- » reflects the company's commitment to the principles of integrated
safety management,
- » is documented, maintained and communicated to employees,
and
- » provides adequate staffing and resources for the proper
implementation of the policy and the ES&H program.
Senior management enforce the policy to the point that they:
- » view a successful ES&H program as a personal achievement
- » include ES&H program as a key component in their strategic
plan
- » regularly discuss commitment to continuous improvement of
ES&H both internally and externally
- » make sure that their CEO and Board of Directors understands
the ES&H program and receives regular reports
- » require all employees to establish ES&H goals and then evaluated
employees on these goals
- » require management systems to be established to support
ES&H and to be updated and improved as needed.
- » participate in peer groups (i.e., DOE's Executive Leadership
Groups) designed to share ideas, goals, etc., and require
other company managers (line and staff) to participate in
similar groups
- » require specific plans with timetables for implementing
ES&H programs and they personally review progress of the plans
- » require regular messages about ES&H programs in site newsletters,
quarterly reports, annual reports, etc.
- » compare their company's ES&H performance against other
DOE contractors of similar size
- PLANNING
The management element addresses;
1) the identification and assessment of relevant regulations and
industry standards, 2) the evaluation of product, process and
distribution risks, 3) the identification and assessment of employee
and community concerns about the organization's environmental,
health and safety performance, and 4) setting priorities and goals
for performance improvement.
Attributes
The organization demonstrates appropriate
planning by:
- » having processes in place for
the assessment of hazards and risks associated with their
products, processes and distribution activities that includes
impact on the environment, personnel and communities,
- » integrating the risk evaluation
process into the research and development of new products
and processes,
- » creating and maintaining a product
information system related to environmental, health and safety
risks,
- » having processes in place for
the systematic review of all environmental, health and safety
related regulations, and their interpretations, that are relevant
to the organization's activities,
- » maintaining documented ES&H
objectives and targets which have clear means, time frames,
and responsibilities for accomplishment,
- » having a system in place for
the identification of needs and allocation of resources to
implement performance improvements, and
- » having processes in place to
assess community and employee concerns about the organization's
activities.
- IMPLEMENTATION, OPERATION AND
ACCOUNTABILITY
This management element addresses
the achievement of objectives and policy expectations. It also
covers the preparation and competence of employees to carry out
their tasks, and documentation that is critical to the execution
of those tasks.
Attributes
The organization demonstrates that implementation, operation and
accountability are part of their management system by the existence
of:
- » a clear definition of responsibility
and accountability for the execution of ES&H tasks,
- » training programs that include
task specific skills and competencies, and awareness of regulatory
requirements appropriate to the task,
- » a process for communication
and dialogue with stakeholders of relevant risks and impacts
of the organization's activities to human health and the environment,
and plans for improving the organization's ES&H management
system,
- » employee involvement in the
development, communication and execution of ES&H programs,
- » documented procedures to ensure
safe operations for all processes, process changes, maintenance,
and product handling and storage,
- » written site emergency response
plans with appropriate considerations of communications and
community recovery needs.
- » participation in the development
of community emergency preparedness planning,
- » a documented process for responding
to chemical distribution incidents,
- » programs to provide appropriate
guidance, information and training requirements to carriers,
distributors, customers and contractors on the risks and hazards
of the organization's products and processes, and for receiving
guidance and information from suppliers on goods and services
used by the organization,
- » processes for the qualification
and selection of carriers, distributors and contractors that
place priority on safety performance, and
- » clearly defined and visible
emissions reduction, pollution prevention, and ground water
protection programs.
- PERFORMANCE MEASUREMENT AND CORRECTIVE
ACTION
This management element deals with
the use of performance indicators, performance reviews, accident
and incident investigation, compliance audits, data records, and
taking or recommending corrective actions.
Attributes
The organization demonstrates the use of performance measurement
and corrective action by having processes in place for:
- » the tracking of emissions and
releases, accidents and injuries, process upsets, and distribution
incidents,
- » reviewing the performance of
all carriers, suppliers, distributors, customers and contractors,
- » the investigation of accidents
and incidents that get at the root causes of occurance and
develop recommendations for prevention or corrective action,
- » the maintenance of sufficient
data files to enable analysis of trends and performance against
goals,
- » the audit or review of compliance
with regulations and company procedures, and
- » the measurement of the effectiveness
of its communications programs with its stakeholders.
- MANAGEMENT REVIEW AND REPORTING
This management element addresses
the manner in which the organization reports its performance to
its stakeholders and senior management, and how the organization
and senior management reviews that performance relative to goals
and makes appropriate changes in goals, policies or priorities.
Attributes
Management Review and Reporting are characterized by evidence
of:
- » periodic reviews of the organization's
objectives and policies for relevance against the organization's
products and processes, the expectations of stakeholders,
the adequacy of resources assigned to ES&H management programs,
and the organization's performance against their goals and
policies,
- » reporting mechanisms to stakeholders,
employees and communities on the organization's ES&H results,
- » bench marking of ES&H management
systems against other organizations, and
- » a performance management system
for employees that recognizes ES&H excellence.
QUESTIONS FOR VERIFYING THE MANAGEMENT
SYSTEM
Sufficient dialogue must take place between
the verifiers and the appropriate managers of the organization to
determine whether the elements of the management process have been
developed, integrated into the organization's activities and are effective
in improving performance. Questions should be asked to directly probe
the significant management process element attributes.
Sample questions, listed below are designed to open dialogue. Bullet
items under the questions are thoughtful probes to lead to further
questions if the necessary information is not forthcoming in the dialogue
resulting from the questions. In some cases the thoughtful probes
define questions to be asked of different functional managers within
an organization. There is also listed the most appropriate attribute
that corresponds to the question and some suggested actions for the
verifiers to go through that can enhance the information gathering
process.
Questions for Senior Management to test Policy and Leadership
The verifiers should obtain copies of appropriate policies and publications
that contain policies prior to the interviews. They should look for
such things within the policies such as references to industry ES&H
initiatives such as ISO 14001, legal compliance or continual improvement.
The verifiers should be very familiar with the policies prior to the
interviews.
- What process have you gone through
to determine if your ES&H policy is relevant to the nature of
your organization ‘s business and takes into account public and
employee inputs? (Attribute A.1 and A.2)
- » Reviewed against industry peers?
- » Have board level review?
- » Make results based judgements?
- » Have employee committees?
- How do you integrate the philosophy
of continual improvement into your ES&H policy and set a framework
for establishing objectives? (Attribute A.3)
- » Set long term goals?
- » Integrate quality and business
management with ES&H management?
- » Make explicit references?
- How do you encompass the range of
regulatory requirements and their compliance in your policy? (Attribute
A.4) (If done through explicit wording in policy this does not
have to be asked)
- How have you worked the principles
of integrated safety management (Attribute A.5) (If done through
explicit wording in policy this does not have to be asked)
- Could you describe your process
for communicating your policy to employees? (Attribute A.6)
- » Periodic reports?
- » Newsletters, bulletin boards?
- Could you describe you process for
identifying the resources needed and staffing required for ES&H
implementation and how you test the adequacy of the resources
allocated? (Attribute A.7)
- » Bottom up?
- » Review with peers?
- Could you describe your personal
role in the communication of your commitment and dedication to
ES&H (Opening paragraph)
- » Speeches?
- » Periodic messages to employees?
- » Industry participation?
Questions for Appropriate Managers
in the Organization to Test Planning
It is not practical to review many documents or manuals prior to these
interviews. However, any brochures, pamphlet, or other publication
that describe the company's product information system should be reviewed
prior to the interviews. Interviewees should be encouraged to use
examples and provide samples of manuals, etc. during the interviews
for reference and illustration.
- Could you describe your process
for assessing product and process risks and how you integrate
it into new research and development? (Attribute B.1 & B.2)
- » Methodology?
- » Distribution?
- » Inbound materials?
- What kind of system do you maintain
for product and process risk data and what type of data is in
the system? (Attribute B.3)
- » Computer based?
- » On-line?
- » Toxicology?
- » Regulatory classifications?
- How does your organization identify
the regulations, legislation and interpretations that are relevant
to your operations (Attribute B.4)
- » EPA?
- » OSHA?
- » DOT?
- » Other government agencies?
- » Trade association activity?
- How are your ES&H goals and targets
maintained and kept current? (Attribute B.5)
- » Specified performance targets?
- » Time frame expectations?
- Could you describe how you identify
staffing and resource needs for implementation of ES&H programs
(Attribute B.6)
- » Bottom up?
- » Peer review?
- How do you identify and assess employee
and community needs? (Attribute B.7)
- » Community Advisory Panels?
- » Surveys?
- » Focus Groups?
Questions for Appropriate Managers
in the Organization to test Implementation, Operation and Accountability
Pre-review of documents and manuals is not practical for this set
of interviews. Manuals and documents should be made available for
casual review by the verifiers and to be used for illustration and
example during the interviews. In this portion of the interviews performance
data may be used to assist in the illustration of programs.
- Could you describe the way your
organization is structured to implement the ES&H program (Attribute
C.1)
- » Responsibility matrix?
- » Accountability?
- Could you describe your organization's
training programs? (Attribute C.2)
- » Job Skills?
- » Environmental, health and safety
training?
- » Compentancy requirements?
- » Training records?
- » Regulatory familiarization?
- Could you describe your communications
and outreach programs (Attribute C.3)
- » With employees?
- » With communities?
- » With stockholders?
- » With customers?
- » With carriers and contractors?
- How do you get employees to contribute
to the outreach and communications programs? (Attribute C.4)
- » Volunteers?
- » Delegation?
- » Training?
- How are your ES&H requirements built
into your process operating procedures(Attribute C.5)
- » Regular HAZOPS?
- » Regular Job Safety & Health
Analysis (JSHA)?
- » Review committees?
- » Employee involved?
- Could you describe your emergency
response plans and your involvement with community preparedness
planning? (Attribute C.6,7 &8)
- » For plant sites?
- » For distribution?
- » LEPC involvement?
- » Testing of plans?
- » Integration with the community
and neighbors?
- What is your process for providing
and receiving risk-related guidance and information to/from your
commercial partners (Attribute C.9)
- » Distributors?
- » Customers?
- » Contractors?
- » Suppliers?
- Could you describe your process
for qualifying and selecting suppliers of services and materials
to your organization? (Attribute C.10)
- » Pre-screening audits?
- » Qualification criteria?
- » Carriers?
- » Toll processors?
- » Subcontractors?
- » Distributors and terminals?
- » Disposal sites?
- Can you describe your emissions
reduction, pollution protection and ground water protection program?
(Attribute C.11) (The use of results and performance data in the
form of graphs and tables may be used as an appropriate tool for
describing the programs)
- » Goals and targets?
- » Stage of implementation?
Questions for the Appropriate Managers
in the Organization to test Performance Measurement and Corrective
Action
Performance data must be used in this portion of the interviews to
demonstrate the tracking processes. (Care must be exercised by the
verifiers to look only at the tracking process and not the level of
performance.)
- Could you describe your process
for tracking ES&H performance? (Attribute D.1)
- » Injury and illness?
- » Process incidents?
- » Distribution incidents?
- » Toxic releases?
- » Regulatory violations?
- How do you track the performance
of your commercial partners and review it with them? (Attribute
D.2)
- » Subcontractors?
- » Customers?
- » Distributors?
- Could you describe your accident/incident
investigation processes? (Attribute D.3)
- » Injury and illness?
- » Distribution?
- » Process incidents?
- » Near-hits?
- » Root causes?
- » Corrective action?
- Do you maintain a data base of all
accidents, incidents and near-hits to facilitate analysis of trends?
(Attribute D.4)
- » Injury and illness?
- » Distribution?
- » Process incidents?
- » Customer reports?
- Could you describe your internal
audit processes for measuring compliance with regulations and
your organization's policies? (Attribute D.5)
- » OSHA?
- » EPA?
- » TSCA?
- » DOT?
- » Other government agencies?
- How do you measure the effectiveness
of your communications and outreach programs? (Attribute D.6)
- » Surveys?
- » Focus groups?
Questions for Senior Management and
Appropriate Manages of the Organization to test Management Review
and Reporting
This portion of the interviews does require pre-review of environmental
reports, annual reports, newsletters, etc.
- What process does your organization
use to periodically review your ES&H policy for relevance and
appropriateness? (Attribute E.1) (This question may be redundant
if adequate answers were provided in the interviews involving
policy and planning)
- » Board review?
- » Senior management review?
- » Bench marking?
- How does your organization review
and discuss your ES&H performance? (Attribute E.1)
- » Management Council?
- » Department meetings?
- How do you determine if the resources
applied to implementation of you policy and attainment of your
objectives is adequate? (Attribute E.1)
- » Results?
- » Board review?
- » Bench marking?
- Could you describe your processes
for reporting your ES&H results to your stakeholders and communities?
(Attribute E.2)
- » Employees?
- » Stockholders?
- » Plant communities?
- » Public?
- Could you describe some of your
bench marking activities within the industry? (Attribute E.3)
- » Managed systems?
- » Performance?
- Have you included ES&H performance
in your employee performance management process? (Attribute E.4)
- » MBO/KRAs?
- » Bonuses?
- » Merit increases?
- » Special forms of recognition?
- » Job description and annual
reviews?
This page was last updated on January 27, 2011
|
