(184b) Performance Based Ehs Assessment Techniques: Focusing on Behaviors and Ehs Performance-Outcomes

Managers use a very broad range of techniques, which will go way beyond the implementation of documented policies, procedures and work instructions to deliver the operational and business outcomes they are seeking (profit, cost control, output volumes and the like). We also understand that the right EHS outcomes will arise if - and only if ? mainstream operational managers apply the techniques they naturally use in the pursuit of their operational goals to address the EHS aspects of the activities for which they are responsible. So, during the course of our assessments, assessors must test if managers are properly integrating EHS considerations into their activities in a way which will reliably avoid incidents and accidents, assure compliance with regulations and continuously reduce impacts on people and the environment. Performance-based assessments start with a detailed site tour, where the assessment team will establish ? through direct observation ? if the organization is producing the right outcomes on the ground. Typically, experienced assessors encounter some level of non-compliance with regulations, examples of poor control of risks and some examples of unnecessary resource usage or waste generation. Assessors should then use root cause analysis techniques to determine the management causes which have given rise to these sub-optimal outcomes they have observed. The content of the organization's EHS management system are integral to this ?bottom-up' analysis.

During the course of ERM CVS assessment, assessors enter into deep discussion with mainstream operational management to establish how they address EHS considerations in the course of their ongoing management of the operations. The organization's EHS management system are used as an agenda for this ?top-down' discussion with management. During the course of our assessments and especially at the closing meeting, we will provide management with a realistic insight into the overall effectiveness of the programs they have established to address the EHS aspects of the operations. Each element of the ERM CVS assessment methodology is described below. Contacts with the Site Prior to Assessments Prior to each assessment, the ERM CVS Client Manager or the ERM CVS lead assessor for the assignment will get in touch with the primary contact at the site being assessed to: · Ensure that they understand ERM CVS' assessment technique and how that can use this to best effect; · Discuss planning for the assessment (start times, attendance of opening and closing meetings, interview schedules, etc.); · Agree logistics. We follow up with a briefing note, which is sent in advance of all assessments to the site contact. We also send a questionnaire to the site to solicit information, which will help to focus the audit team's efforts. The Opening Meeting During the course of a 30 minute opening meeting the ERM CVS lead assessor will confirm assessment scope and the program for the assessment and ensure that management understands that they will be receiving feedback on the practical effectiveness of their established EHS programs and the level of support operations and other personnel provide to this aspect of the organization's activities. The Site Tour and Causal Analysis Inspection of the operations focusing on physical infrastructure and areas of special interest in terms of the EHS aspects of the operations, during the course of which our experienced auditors will inspect the facilities and seek - through direct observation - evidence of sound and unsound EHS management practices. We encourage our clients to take photographs of issues we identify for use in the closing meeting and subsequently for their own training purposes. The assessment team will carefully select a number of these observations and use sophisticated root cause analysis techniques to determine the operator and management behaviors which have given rise to them. The Business Performance Review Review of overall business circumstances and emerging conditions. Areas of focus include financial performance, market conditions, customers, and operations development. An insight into these issues will provide the assessment team with an understanding of the business context and pressures within which EHS management takes place; likely to be vital to understanding the strengths and weaknesses in the management of EHS issues within the operations. EHS Management Review The top-down EHS management review completes the picture. A series of relaxed but searching interviews ? mostly with mainstream operational managers ? will provide the assessment team (and on-site management) with an insight into the most effective management techniques employed within the operations and the extent to which these techniques are employed to address EHS aspects of the operations. A marked contrast between the approach to mainstream operations and EHS management often ? but not always - emerges. During the course of the EHS management review the assessment team will typically interview senior management on site as well as production managers, EHS specialists, legal experts, finance, human resource and training management, performance improvement managers, facilities engineering and maintenance personnel, those responsible for land management, procurement specialists and contract management, operators and contractors. The ISO and/or OHSAS standards are used as an agenda for the EHS management review which will be populated with observations and information collected during the course of the site tour and business performance review. Reporting Working closely with personnel on site, the assessment team will prepare a presentation for the closing meeting and a written report setting down a summary of issues reviewed during the assessment and any weaknesses in EHS management which may have been identified by them. Our findings are normally set down in four parts: · Relevant facts: the assessment team's observations that are relevant to this finding (for example a regulatory non-compliance or an observed poor practice). · Consequences: Statements regarding the possible consequences of an observation will be included where appropriate. · Identified management weakness which needs to be addressed: description of the ultimate cause or causes of issues which were observed. · Clause of the standard: the relevant part of the ISO 14001 or OHSAS 18001 standard. Meeting with Senior Management Prior to the closing meeting, the ERM CVS Lead Assessor will meet with the top-most manager for the operations and present their findings for the assessment to them. The primary purpose of this meeting is to provide senior management with an opportunity to digest the assessment findings, in advance of the closing meeting. Closing Meeting Presentation Our closing meetings are designed to provide the site leadership team with a realistic insight into the overall effectiveness of the programs they have established to address the EHS aspects of the operations and a sense of how weaknesses in them may impact the business. We describe how we have spent our time on site and the observations that we have made during the course of the assessment. Wherever possible we use a selection of photographs of issues observed during the course of the site tour in this part of the presentation. We will provide feedback on the extent to which mainstream management are driving EHS aspects of the operations and specific weaknesses in the mechanisms employed by them in this regard. Our goal: to ensure management understand how their behaviors and the mechanisms they have established are influencing operator behaviors and the practical effectiveness (or otherwise) of these in delivering control of EHS risks, compliance with regulations and ongoing reductions in EHS imp