Corporate-Level Processes

At the corporate level of an organization, the architecture of the requirements flow down process is commonly defined. The corporate-level processes include defining the policies and rules on how the flow down process will be conducted and the associated roles and responsibilities. These corporate-level policies should include detailed descriptions on how the requirements flow down process will function, including clear definitions of the following:

• • Regulatory responsibilities areas within the organization
• • Roles and responsibilities of regulatory responsibility areas
• • Stakeholder review process membership
• • Authorities for decision-making within the stakeholder review process
• • How stakeholder reviews, decisions and implementation strategies are documented
• • Requirements tracking

It is important that this process be well defined and openly communicated throughout the organization so that it is clearly understood how requirements and requirement flow down are governed. Establishing a clearly defined requirements process builds efficiency into the organization by providing a consistent process for identifying requirements, determining applicability and developing implementation strategies. The efficiencies that can be realized from a well-defined requirement flow down process can be greatly enhanced if the process is integrated into or parallels existing corporate processes. In other words, if the process for governing environmental requirements can be integrated into an already existing corporate process, there will be an inherent level of familiarity to personnel. This approach is preferred to creating a whole new and separate process for environmental requirements that would require an increased expenditure of time and effort for development, documentation and training. The ability of a company to integrate an environmental requirement flow down process into the organization is of course highly dependent on a multitude of variables. Smaller companies or companies with minimal regulatory requirements are most likely faced with an easier challenge of governing environmental requirements. Larger companies operating in highly regulated industries have increased compliance obligations and a greater need for a well-defined and integrated requirement flow down process. In either case, it is important that there is a consistent approach for environmental requirements flow down into each relevant level of the company.

Organization-Level Processes

Activities that should be established at the organizational level to support requirements flow down need to include identifying personnel to fulfill the roles defined at the corporate level and establishing organization-level protocol or procedures that interconnect and complement the corporate-level process. For organizations that are identified as regulatory responsibility areas, the following actions should take place or at least be strongly considered, depending on the size of the company and available resources:

• • Assign a regulatory responsibility area lead
• • Define organization-level roles and responsibilities for regulatory responsibility area lead
• • Assign regulatory SMEs (Note: This may also occur at the work unit level.)
• • Define roles and responsibilities for SMEs
• • Identify training and qualification requirements for area lead and SMEs
• • Identify procedures and instructions needed to integrate with corporate process

For organizations within the company that are not identified as a regulatory responsibility area, the following should be established to support the requirements flow down process:

• • Identify representatives to participate in the stakeholder review process
• • Define how decisions resulting from stakeholder reviews will be communicated internally
• • Define processes for incorporating requirements and implementation strategies approved by the stakeholder review process

Depending on the size of the company, there may not be a need to go beyond the organizational level of the company for establishing processes and identifying personnel to support the requirements flow down and stakeholder review processes. What really dictates the level of organizational participation is how adequately identified requirements and implementation strategies are being communicated to the relevant parts of the organization. Another important aspect that needs to be considered is the adequacy and appropriateness of the implementation strategies. If the people responsible for implementing compliance strategies are not involved in the decision-making process or are not afforded a means to provide input, then there is a high probability that the implementation strategies may not be effective. While ineffective implementation strategies may not always result in a regulatory noncompliance, they certainly can if they are not corrected or revised to adequately apply to the intended work process. Revising an inadequate implementation strategy requires identifying why it is inadequate, making the appropriate changes and going through the stakeholder review process again. This would obviously require additional time and resources and can be avoided the majority of the time if the people performing the work have input into the development of the implementation strategies affecting their work activities.

Work Unit–Level Processes

Integrating work unit-level organizational aspects into the requirements flow down process can be very beneficial to companies that have a large number of regulated work activities or processes across multiple organizational elements. To better understand what a work unit level might look like within an organization, Figure 5.5 provides an expanded version of the example organization chart for Company ABC. As depicted in the figure, work unit levels within an organizational structure are typically defined by a definitive scope of work and associated roles and responsibilities. For instance, Company ABC’s environmental organization consists of a Water Monitoring Group responsible for wastewater and storm water and an Air and Waste Group responsible for air regulations and hazardous waste.

The Health and Safety Group has a similar internal structure with an Industrial Hygiene Group and an Industrial Safety Group. The point to be made here is not

FIGURE 5.5 Organizational work unit levels.

necessarily how to divide responsibilities within an organization but to illustrate that each of the groups at the work unit level has defined areas of responsibility and needs to be integrated into the requirements flow down process. The importance of work units participating in the requirements flow down process should not be limited to organizational elements that are regulatory responsibility areas. Other organizational elements may have activities or processes that require implementation of approved strategies to ensure compliance with environmental regulations and may also need to be integrated into the overall flow down process at the work unit level. In Figure 5.5, the organizations that have been identified as regulatory responsibility areas in previous figures are on the left of the organization chart. As previously stated, these areas are responsible for identifying and tracking applicable regulatory requirements within their respective areas of responsibility and communicating this information to the stakeholder review process. On the right side of the organization chart are examples of organizational elements with work units that are responsible for implementing regulatory requirements that apply to their activities and processes. As previously discussed, all of the organizational elements participate in the stakeholder review process and are responsible for developing protocols and identifying roles and responsibilities within their organization that integrate into and support the corporate-level requirements flow down process. For companies that include integration at the work unit level, this will require:

• • Defining work unit-level roles and responsibilities
• • Assigning regulatory SMEs (Note: This may also occur at the organizational level.)
• • Defining roles and responsibilities for SMEs
• • Identifying training and qualification requirements for SMEs
• • Identifying work unit-level procedures/instructions tailored to specific operations and work processes

Figure 5.6 illustrates how information regarding a new air regulation requirement would flow through our example of Company ABC. As can be seen in the figure, requirements identification and flow down would start at the work unit level within the environmental organizational element that is a regulatory responsibility area. The air regulations SME within the Air and Waste Group identifies a new' requirement and communicates that information up to the environmental area lead who w'ould in turn introduce the requirement to the stakeholder review process. The stakeholder review committee determines applicability and develops corporate-level procedures and/or implementation strategies.

These corporate requirements are then flowed down to all organizational units via their respective stakeholder committee members and each organization then develops work instructions that are tailored to their specific work activities or processes as applicable.

Establishing a requirement flow' down process provides a means for companies to consistently and efficiently communicate regulatory requirements to all relevant elements of the organization. A company’s ability to consistently progress from the

FIGURE 5.6 New requirement information flow.

identification of regulatory requirements to the implementation of effective compliance strategies is an important element of a sustainable environmental compliance program. In order to ensure consistency in requirements flow down, the process including roles, responsibilities, information flow and authorities must be documented and readily accessible to all organizational elements.

Applied Learning

Review the case study and respond to the questions that follow.

5.3.1 Case Study

Company X designs and builds various components for the aircraft industry. The company has 200 employees and all of its operations are conducted in a single facility. Company X purchases its raw materials and supplies from multiple vendors and has them shipped directly to the factory. Some of the components manufactured by Company X include electronics that are completely designed and assembled within the company’s factory. The manufacture of the electronic components requires use of solvents and plating solutions that must be managed as hazardous waste when disposed of. The company also manufactures specific components that are fabricated from various metal alloys that require welding, machining and the application of special epoxy resins, paints and other finishes. The application of these epoxies, paints and finishes must be conducted in an environmentally controlled room that discharges air emissions up an exhaust stack. The electronics operation and the metal fabrication operation both discharge rinse water into a regulated wastewater system. Once the components are assembled and inspected, they are shipped to various aircraft companies around the world.

• 1. As the environmental compliance manager for Company X, how might you organize the environmental group or department?
• 2. What type of environmental compliance issues might apply to Company X?
• 3. What suggestions would you make to your management regarding the integration of environmental compliance into the Company X organization?
• 4. Which elements of the Company X organization might be affected by new or changing environmental regulations?

References

Carlile, Liz. (2011). Report. International Institute for Environment and Development, 2011.

JSTOR. Accessed February 25,2020. www.jstor.org/stable/resrep01461.

Thompson, Leigh, & Brajkovich, Leo F. (2003). Improving the creativity of organizational work groups [and executive commentary]. The Academy of Management Executive (1993-2005), /7(1), 96-111. JSTOR. Accessed February 25. 2020. www.jstor.org/ stable/4165931.