Lecture 5: 22 March 2014

I started the lecture with a recap of what we had learnt about ISO-14001;  we discussed various elements of an environmental policy and the elements of planning like aspects and impacts, legal and other requirements and objectives, targets and programmes.  We moved on to discuss  various elements of the "implementation" or "DO" part of the Environmental Management System.  This section has 7 sub-sections.  We discussed each one of this briefly.

4.4.1 - Resources are to be provided by the management for establishing, implementing and maintaining the Environmental Management System - these resources are human resources, financial resources, infrastructure and information. The top management has to appoint a Management Representative to establish, implement and maintain an Environmental Management System and to report to the management periodically about the effectiveness of the system.

Role is the part played by employees apart from the functions for which they are responsible or results for which they are accountable to. An employee, for example an Accounts Officer, may take the role of an internal auditor or a trainer even though his main responsibility is in Accounting. ( We discussed the ROLE played by individual in real life - a man is a husband to his wife, is a brother to his sister or brother, is a son to his parents, is a friend to his friends etc. These are various roles he plays in his life).

In order to ensure that the system is effective the management should document the responsibilities and authority (to take actions, decisions etc.) and make it known to all concerned employees.

4.4.2 - Competence of employees who are responsible for activities related to identified significant aspects need to be ensured; competence is related to qualification, training and experience.

ALL employees have to be trained to understand the policy, procedures and other relevant elements of the EMS. ALL is the key word here.

Employees who are responsible for activities that have potential significant impacts have to be competent in terms of education, experience and training to carry out that function.

4.4.3 - Communication is of two types,

(a) internal communication with employees and contract workers working within the premises and
(b) external communication with stakeholders outside the organization, like the Government Departments, Statutory bodies, NGOs, Banks, Neighbours etc.

Procedure for both internal and external communication should be effective (e.g. the internal communication should ensure that the recipient of the communication has understood the content of the communication). The procedure for external communication should address the receipt and response to communication from external stakeholders. The organization should decide whether to communicate its significant environmental aspects to external stakeholders and record its decision.

One method of external communication is the Global Reporting Initiative (GRI) guideline based Sustainability Reports.

4.4.4 - Documentation - Information with its supporting medium (paper, magnetic tape, CD, DVD etc.) is a document; Records are a sub-set of documents.

Procedures, Policy, Objectives/targets/programmes etc., with the medium on which they are captured are documents. Information on the past activity, including measurements, reviews etc., are RECORDS. While documents, except RECORDS, could be changed, RECORDS cannot be changed/altered.

Documents, including Records, are used as evidence of the working of the Environmental Management System. Environmental Management System Manual, capturing various elements of the EMS is one such document (ISO-14001 does not prescribe a written manual, but for better working of the system a written manual is recommended)

4.4.5 - Documents are controlled; that means that the documents are checked for their authenticity and are verified and approved by those authorized to issue documents.

This procedure is necessary to avoid obsolete documents being used in the organization. Current documents need to be available at the all places where related work is carried out.

Control is also required for documents which have external origin (e.g. standards, legal documents etc).

4.4.6 - We discussed issues related to operational control procedures that are established to address significant environmental aspects, Procedures have to established for those activities which can cause environmental impact. These procedures identify the scope, responsibility, and the "how" of doing things.

These procedures also apply to contractors and suppliers where relevant. Procedures need not be just a summary of what has to be done; they can also presented in the form of flow-charts for clarity. Procedures should also identify the "operational Criteria" - operational criterion is that indicator which provides information for action that reduces the environmental impact.

4.4.7 - We discussed issues related to emergency/accident procedures and the consequence of the procedure. Incidents are indications of what is expected in days to come. Accidents and their analysis for prevention will help an organization Environmental emergency situations are those where the surrounding populations have to be evacuated or the emissions/discharges can pollute the ground water around.. One needs to take precautions while using emergency measures; they should not lead to other environmental issues

Lecture 4 : 15 March 2014

We started the class by recapitulating the concept of CSR that we have studied so far.  What we studied so far is about "what" is CSR or Sustainability.

Now we have to move to "how" of CSR/Sustainability.

The syllabus covers ISO-14001, OHSAS - 18001, SA 8000, AA-1000, Global Compact, ISO 26000 etc.

I explained to you that  a  system based on Plan-Do-Check-Act  (PDCA) cycle is suggested for ISO-14001 and OHSAS 18001; most of the activities (especially improvement activities) can be explained in terms of PDCA (also called Deming's cycle). I explained to you how a simple activity of  attending the class has inherently all the elements of PDCA.

We agreed that we will study one of  these standards a little in depth and the others not in detail.

We also agreed that we will study ISO-14001 (2004) in details.

Sections 4.2 to 4.6 are the operative parts of the standard ISO-14001: Environmental Management Systems: requirements with guidance for use.

Section 4.2 is about the Environmental Policy.

I explained to you that Policy is the statement of intent of the organization and that subjects that have potential to cause risk to the organization are covered through policies.

Section 4.2 of ISO-14001 requires that the Environmental Policy is appropriate to nature of the business of the organization and the policy

a) is issued by the top management
b) shall commit the organization to prevent pollution
c) shall commit the organization to comply with applicable legal and other requirements
d) shall commit the organization to continual improvement
e) shall provide a framework for setting and reviewing objectives
f) is documented (we will discuss what is documentation later)
g) is communicated to employees and others like contractors and suppliers
h) is available publicly

I explained to you various terms like "top management","prevention of pollution" "continual improvement", "other requirements", "framework", "communication", and "available publicly".  To recap:

Top Management : Person or persons who has the ultimate control of and responsibility for the organization
Prevention of Pollution: Prevention includes reduction of pollution; i.e. reduce or prevent pollution through different means/techniques
Continual Improvement:  Improvement of the overall environmental management system brought out by improvements in various sections of the organization's activities, products and services
Other requirements: Requirements, which are beyond legal requirements, that include requirements of customers, stakeholders, industry associations etc.
Framework: A system of procedures and processes that helps to address specific issues
Communication: A process of transmission of information,confirming that the transmitted information has reached the desired audience and that they have understood the information (a two way process)
Available Publicly: The document is not a restricted document, but is available to anyone who would like to have access to it.

I have shown to you as to how to write a simple ISO-14001 compliant Environmental Policy:

(Example of a simple Environmental Policy)

"ABC Company Limited is involved in the manufacture and sale of .....................

Our environmental policy which is applicable to all employees of the company as well as those working for or on behalf of the company is as follows.

We commit ourselves
1.  to prevent pollution of air, water and soil
2.  to comply with all applicable environmental  laws and other requirements
3.  to continually improve our environmental performance

We shall establish and maintain an ISO-14001 environmental management system


sd.
(Managing Director)
Date:        

As an exercise you may like to search for environmental policies of various organizations in their web site and study them.

Next we have taken up for discussion section 4.3 which is about Planning.

Planning is the most important part of any systematic activity.  I quoted: "If you fail to plan, you plan to fail".
If proper attention is given to details during this phase, the progress of work in the later parts of the system will be effective (i.e. achieve the goal) and efficient (i.e. in time with the least available resources).

Section 4.3.1 is about Aspects and Impacts, their identification and evaluation.  An Impact is a change in the physical environment (air, water, soil etc., including flora, fauna, called receptors) that is caused (or likely to be caused) by the activity, product or a service of the organization.  An  Aspect is that element of the activity, product or a service, that causes that impact.  For example, when you drive your vehicle there is an emission from your exhaust pipe which pollutes (changes the characteristics of) the air around.  Here "Driving the Vehicle" is the activity.  "Emissions from the exhaust" is the Aspect.  "Air Pollution" is the Impact.  Thus there is a "Cause" and "Effect" relationship between "Aspect" and "Impact".  We can identify "Aspects" and "Impacts" for products too.  For example, take a refrigerator.  The design of the refrigerator determines its energy consumption, which in turn determines its contribution "Green House Gas" emission at the thermal power plant.  In this case, Refrigerator is the Product.  Green House Gas emission is the Aspect.  Global warming is the impact.

It is important to understand that we study aspects and impacts of those activities, products and services on which the organization has control or which it can influence.

Once ALL the aspects and impacts have been identified, it is necessary that they are evaluated for their significance.  This is required because such an evaluation helps the organization to identify those aspects that are "significant" and act on them.  For this class, it is not necessary to go into the details of assessment of aspects; what should be understood is that methods are available for identifying significant aspects and these significant aspects are important in establishing and maintaining an EMS.

It is also required that the organization identifies the link between significant impacts and "legal and other requirements".  For example, if the organization has identified emissions from a process to be a significant aspect and air pollution arising out of it as significant impact, it is expected that it links the impact to requirements of, say, Air (Prevention & Control of Pollution) Act (with respect to emission standards).

Section 4.3.2 is about identifying and accessing the legal and other requirements.  In India most of the applicable environmental  legal requirements are available at: www.moef.nic.in.  Other applicable legal requirements (such as Explosives Act, Motor Vehicle Act, Petroleum Act, RoHS, WEEE,  etc., ) have to be identified based on the significant impacts identified in section 4.3.1.  It is not enough if the organization identifies these requirements, they also should know as to how to access them.  These have to be documented.

4.3.3 is about setting objectives, targets and establishing programmes to meet the objectives/targets.  This section is an important section in planning.  Objectives (long term goals) have to be arrived at by considering the Environmental Policy, significant aspects, resources (money, man power, technology) available and legal and other requirements.  For example based on the evaluation of aspects, the organization may identify "discharge of substance A to water" as a significant aspect.  The Environmental Policy commits the organization to "prevent pollution".  The organization may set an objective of "Zero discharge of substance A" to water in four years as the objective, based on information on technologies available, funding available and man-power available.  Targets (short term  goals) can then be set to achieve them with the available resources.  For example, in the above case, the immediate target for the next year can be "reduction of discharge of A into effluent by 20 % by improving process parameters".  Both Objectives and Targets have to be SMART (Specific, Measurable, Achievable, Relevant,Time bound).

Once Objectives and Targets have been identified the organization should establish Environmental Management Programmes (EMP) to achieve these goals.  The programme should have the following characteristcs: What has to be achieved (objective) ?    What is the time frame to achieve the goal ? Who is responsible for what ? What are the resources available/required for the programme ? What are milestones to be monitored ?  What are the key performance indicators for monitoring and reviewing the programme ?

Environmental Management Programme helps the organization to address significant environmental issues so as to avoid risks to the organization;  EMP may also provide new opportunities to the organization, like improving efficiency, reducing waste etc.

We will take up the other sections of ISO - 14001 in the next class.

CSR Class on 08 March 2014 - I will not be able to take this class

Dear Friends,

I will not be able to take the CSR class on 08 March, 2014.  Please bear with me.

Please inform other students too.

Kind regards,

Ramakrishnan

Lecture 3 - 01 March 2014

We started the class with a discussion on the Tutorial  (given in the earlier post).

We recalled the three functions of the environment, three characteristics of the environment that cause potential conflicts and the three conflict resolution techniques.

I explained to you that environmental issues for business arise through out the life cycle of a product.  Like human beings, products also have a life-cycle and they follow almost the same pattern of events.  For example, human beings are conceived, delivered, age (i.e. used / put to use), and at the end-of-life sent to a crematorium or a burial ground; some donate their body parts after their death.  Similarly products are designed, manufactured and sold, used and at the end-of-life either land-filled or incinerated; some products are so designed that their parts can be recycled, reused or re-manufactured.  The last option is possible only when these features are in-built in the product during the design of the product.  Such a design which takes care of environmental performance while at the same time makes the product economically attractive is called Eco-design.  As you are aware, manufacturing results in emissions and discharges and generation of solid and hazardous wastes.  The extent to which resources are used in manufacturing, pollutants are emitted or discharged and  wastes are generated can be guided by the design of the product and its manufacturing; eco-design helps to reduce emissions, discharges, generation of wastes etc., during the manufacturing; it also helps to avoid toxic substances in the product and processes.  It helps to improve energy efficiency of products and to reduce the mass of the product continuously.  Such improved performance of products lead to improved environmental performance throughout the life-cycle.  Eco-design also aims at reducing packaging mass and eliminating toxic materials  (e.g. PVC blister packing) from packaging. Design for dis-assembly (a concept used in eco-design) ensures that products at the end-of-life can be easily dismantled and components are amenable to recycling and reuse.

We discussed as to how the conflict situations arising out of the characteristics of environment, viz., common property, multiple use, un-covered cost can be seen arising out of the use of  products like the cell-phone (other examples are cars, cigarettes, music systems, public address systems)

After a short discussion on life-cycle environmental impacts of products, we discussed various protocols related to social issues.  They relate to labour issues (ILO declaration on fundamental principles and rights at workplace ), human rights (Universal Declaration of Human Rights) related to wages, working conditions and corruption (UN Convention against Corruption).  I explained to you that the Companies Act 2013, Schedule VII activities cover almost all the Millenium Development Goals (MDG) of the UN.

We have been studying and discussing the paper "Competitive Advantage of Corporate Philanthropy" by ME Porter and MR Kramer, Harvard Business Review, December 2002, in our last two classes; we agreed that the next tutorial is about "Competitive Advantage of Corporate Philanthropy" based on this paper.  For the second tutorial you may start preparing now; you have to prepare one A-4 sheet write-up on the topic. You may refer to the material available in the above referred paper or from any other source.  You should be able to support or reject the hypothesis that Corporate Philanthropy can be advantageous to a company.  I shall inform you the date for submission of this tutorial later.

Tutorial 1

This is the first tutorial for  the CSR class 2014.

I explained to you the details of Schedule (VII) of the Companies Act 2013.  There are ten activities identified in the Schedule that can be taken up for CSR activities by companies.

I have asked each one of you (not in a team/group) to propose 5 CSR projects falling within the Schedule VII activities for a company which has to spend Rs.10 crores in the financial year 2014 -2015 (i.e.year starting from 1 April 2014).  Your proposal should clearly explain the project and its specific details with the budget requirement.  Your tutorial should be presented in not more than one A-4 size sheet. You should submit your completed tutorial paper to your course coordinator, preferably as a soft copy before Saturday, 08 March 2014.  Please note that marks will be deducted if the tutorial submission crosses one A-4 size sheet; marks will also be deducted if "copying" or "team work" is inferred by the teacher.


An extract of Schedule VII is given below.  These are activities that can be included in the CSR policies of companies.

i) eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation and making available safe drinking water

ii) promoting education, including special education and employment enhancing vocational skills especially among children, women, elderly, and the differently abled and livelihood enhancing projects

iii) promoting gender equality, empowering women, setting up homes and hostels for women and orphans, setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups

iv) ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro-forestry, conservation of natural resources and maintaining quality of soil, air and water

v) protection of national heritage, are and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional arts and handicrafts

vi) measures for the benefit of armed forces veterans, war widows and their dependents

vii) training to promote rural sports, nationally recognized sports, para-olympic sports and Olympic sports

viii) contribution to the Prime Minister's National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women

ix) contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government

x) rural development projects