As a living system, a company’s risk profile is continually shifting. The growing attention on sustainability and corporate responsibility (CSR) has stretched companies as they wrestle with ways to characterize and manage their sustainability and CSR risks.
Integrated EHS, sustainability, and CSR management systems provide a robust structure to manage risks. A key concept in an integrated management system is “the management of change” (MOC), which focuses on identifying and managing risks as operations or the operating environment change. MOC procedures and process typically kick in when new equipment or manufacturing lines are installed, during mergers and acquisitions, or during internal re-organizations. On the corporate responsibility front, forward-thinking companies include the monitoring of third-party monitoring criteria in their MOC process.
Strong MOC processes are part of a company’s first line of defense for risk reduction. The MOC process should detect most risks that arise in between formal risk assessments.
Formal EHS management systems, such as ISO 14001 or OHSAS 18001, handle MOC in various ways. The International Labour Organization’s (ILO) OHSMS and ANSI/AIHA Z10 each have specific sections that address this issue with robust language. OHSAS 18001:2007 has robust language, but no section devoted to MOC, and ISO 14001 is ripe for improvement. The ILO’s MOC language is the most comprehensive and is recommended for use in developing an integrated EHS, sustainability, CSR management system.
A way to improve your MOC process is to incorporate organizational learning and systems thinking tools in it. With this upgrade, there is increased ability to respond to risk profile changes more quickly.
When systems thinking is incorporated in a MOC process, the criteria for initiating the process and methods used during it expand; this is especially important with sustainability and CSR risks. There is an increased understanding of the macro-, meso-, and micro-level environment and systems that affect the company. At the macro-level are a company’s communities, regulatory environment, and financial markets. At the meso-level are supply-chains, actions of competitors, and activities at the corporate level. Finally, at the micro-level are activities within a business unit, department, or team.
With the use of systems thinking tools and practices, such as causal-loop-diagrams and discipline in completely vetting a situation before moving to solutions, a deep understanding of root causes and their links bolsters a MOC process. The ANSI/AIHA Z-10 management system standard points to this in §4.4.A with the requirement to identify intermediate steps in implementation plans. By identifying these steps, a causal link roadmap is started that can help with management-of-change activities. The use of loop diagrams with this increases effectiveness.
EHS professionals have been performing risk assessment and MOC for years. With their experience and structures serving as a foundation, they can make a significant contribution to their company’s sustainability and corporate responsibility efforts. Organizational learning and systems thinking tools and practices provide help with this.
© Redinger EHS, Inc. (2010)
