Document bBnRYnRq3n7bV1ND7pLEJ91pZ
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DATE:
June 18> 1997
subject: REFERENCE:
Establishing ESH Policy For The New Company
T0: Jim Collins - F2EF Jeff Felder - F2EC Mike Foresman - F2EA Garth Fort - F2EI Steve Hacker - F2EP John Henshaw - F2EP Dan Jaffe - A2NH Max McCombs - F2EP Jim Mieure - F2EC Melanie Price -1440 Tony Sardella - 5080 Gene Stevens -1260 John Wiley -1690 Colin Wiltshire - 5045
cc:
Attached is the most recent copy of the presentation to the Chemical Leadership Team on establishing ESH Policy for the new company. Also included is the work done on analyzing the Pledge Guidelines and their continued value under a Chemicals Company program.
The Leadership and Policy teams have given approval to the recommended standard of care and the commitment statements. We now need to engage the businesses, O.E., and other business process leads in developing the specific strategy and tactics that complete our policy/guidelines package.
In order to move to the next step, we plan two approaches:
The business unit ESH contact should set a time for a review with each
business leader and his/her team. I believe it is best that Garth and/or I make
the initial presentation.
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6/18/97 Memo Page 2
2. The regulatory leads will take up the discussion at their regional site managers meetings and with the ESH site leaders.
We should accept the decision of the Leadership and Policy teams on the commitment statements, and engage the businesses and O.E. in consensus building of the specific strategies and tactics under the commitments. I would expect that a successful first meeting would produce:
Further comments on the commitment statements.
An agreed process within each business on how to build strategies and tactics.
A schedule to complete the work by 10/1.
We can discuss this further at our staff meeting on 6/27, but you can proceed to set
meeting dates with the businesses after 6/27.
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Attachment
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STLCOPCB4032764
PRESENTATION
Value Alignment
Desired Outcomes Options Discussed
Commitments
Statements Strategies
i
What do we retain?
What do we discard?
What do we add?
"Does Improving A Firm's Environmental Mangement System Result in a Higher Stock Price?" Study, real-world data 300 Largest US companies - Feldman, Soyka and Ameer
Conclusions: Sound Environmental management leads to reduced risk and risk reduction is valued by financial markets...can increase stock price by 5%... Reasons: Direct cost reduction benefits... Perceived as being less risky business entities... ...therefore are accorded a lower cost of capital Key: Excellence must be recognized by market... communications of plans /progress critical
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The Most Relevant Analyst Questions Strategy arid Vision Does the company have a global environmental policy? Is there an environmental program with objectives and measures? How is progress measured versus main environmental problems/opportunities of
the company? What is the impact of environmental strategy on shareholder value? Does implementation fall into line responsibility? Is the company alert to emerging environmental issues? How does the company deal with risk and crisis management?
Market Value vs. "Quality" of ESH Effort
Total Resources
Shareholder Value Pyramid
Shareholder Vahe Vahe
Contributors Value Drivers
OSW 122a24 STLCOPCB4032769
ISSUES Standard of Care Pledge Items Dropped Decision on New Elements Internal Approval Process
Desired Outcomes
Produce a Strategy / Plan That:
Results in safe and sustainable operations and products
Complies with regulations
Results in a motivated work force that drives continuous improvement
Maintains existing credibility with all audiences and is valued by them
Maintains momentum
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Is clearly integrated with company mission statement
Causes the ESH components to be viewed as a contributor to achieving financial goals via risk management, cost management, new business development, etc.
STLCOPCB4032772
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REGULATORY: ASSETS: PRODUCTS: PEOPLE:
COMPLY w/FINES FUNCTIONAL SALEABLE HOLD HARMLESS
PROCESS:
RELIABLE
COMPLY RISKS TOLERANT SAFE TO EMPL. ACCEPT IN
AVERAGE
COMPLY 100%
COMPLY 100%
RISK ADVERSE
RISK ADVERSE
SAFE TO CUSTOMERS DIFFERENTIATED
INJURY/ILLNESS RATE INJURY/ILLNESS
LOW
FREE
HIGH YIELD
INPUT = OUTPUT LOW RISK
STANDARD OF CARE
ACCOUNTABLE PROTECT
RESPONSIBLE
SHORT TERM FOCUS ON INCOME VS. LONG TERM LIABILITY
DEFERRED CAPITAL MEETS INDUSTRY
SPENDING
EXPECTATIONS
AVG. COST AV. VALUE.
MOTIVATED EMPLOYEE
LOWER COSTS
DECENTRALIZED POLICY MAKING
SUSTAINABLE
LOWER COSTS
LEADER
CREDIBILITY REQUIRES SHORT TERM INVESTMENT LONG TERM NET VALUE
SHOULD ALIGN WITH GROWTH PORTIONS OF PORTFOLIO
PREMIUM PRICE FOR PRODUCTS
OUTCOMES
STANDARD OF CARE ACCOUNTABLE PROTECT RESPON.
SUST.
MAINTAINS MOMENTUM
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- 0+
MAINTAINS CREDIBILITY
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- 0+
INTEGRATED WITH BUSINESS MISSION
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SAFE & SUST. OP. & PROD.
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MOTIVATED EMPLOYEE
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STLCOPCB4032773
ESH VIEWED AS CONTRIBUTOR
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A "PLEDGE-LIKE" STATEMENT:
We will ensure our operations are safe and pose no undue risk to employees, customers, the environment and communities.
We will make products that are safe for intended use and sustainable.
We will keep our operations open to our communities, and foster open communications with all of our stakeholders.
We will continue to improve the sustainability of our businesses by improving their economic and environmental efficiencies.
We will encourage active participation in and positive contributions to environmental areas by our employees.
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STLCOPCB4032774
COMMITMENT:
We will ensure our operations are safe and pose no undue risk to employees, customers, the environment and communities.
STRATEGY:
Achieve total compliance with ESH requirements while striving to achieve incident/injury free operations over 10 years.
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COMMITMENT:
We Will make products that are safe for intended use and are sustainable.
STRATEGY:
Fully implement Product Stewardship Code of Responsible Care and reviewed by management by the end of 1998.
A Sustainability Assessment will be required for all new products.
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STLCOPCB4032776
COMMITMENT:
We will keep our operations open to our communities, and foster open communications with all of our stakeholders
STRATEGY:
We will maintain proactive dialogue with employees, customers and the public worldwide on ESH matters.
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STLCOPCB4032777
COMMITMENT:
We will continue to improve the sustainability of our businesses by improving their economic and environmental efficiencies.
STRATEGY:
Systematically increase raw material and energy efficiencies (make more or less) Search for technology and operational improvements Maintain 90% air commitment
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COMMITMENT:
We will encourage active participation in and positive contributions to environmental areas by our employees.
STRATEGY:
Use special enterprise recognition programs and site-specific initiatives.
NEW ELEMENTS
Sign CERES
Replace Deep Well Policy with "Make more with Less"
Add "New Product" sustainability
Compliance Process date
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STLCOPCB4032780
Decision/Communication Plan
Policy Committee Decides on "Standard of Care and Commitments
Operations/Leadership Committees build the Strategy/Tactics
Internal and External Communication Plan
June
Aug./Sept. Sept/Oct.
CROSS REFERENCE: Pledge Manual and Responsible Care
Pledge Manual
Responsible Care Codes
Pollution Prevention
Pollution Prevention, Practices 1 through 11, except Nos. 4 and 8
Employee and Community Safety and Health
Process Safety Employee Safety and Health
Process Safety and Emergency Response
Product Stewardship Chemical Distribution Groundwater and Soil Quality
Community Awareness and Emergency Response Process Safety
Community Awareness and Emergency Response
Product Stewardship Distribution
Pollution Prevention, Practices 13 and 14
Outside Processors
* Community Awareness at Manufacturing Sites
Pollution Prevention, Practice 12
Pollution Prevention, Practice 12
Community Awareness and Emeregency Response, Practices A1 thru A9
Pollution Prevention, Practices 4 and 8
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STLCOPCB4032782
Sheetl
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Pledge Program
1. Commitment: Safe Operations, No Undue Risk (Includes 1 Envi ronnlenl al Ris VThreat Containment)
Program Element
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' ' ' ' ...... i ' ' " ..... . Recommendation
~'1 1.1
Policy for Zero Effect PCB-Free in the U.S.A.
-- XX X
X KEEP. Integrate into Commitment statement. Revise. Essentially done. Change to a maintenance-oriented requirement.
1.3 13 . 1.3 1.3 1.3
No landfill of acutely hazardous or incinerables Manage wastes as if they were hazardous, if criteria met Medical Wastes to be incinerated, manifested Monsanto not a commercial waste disposer Land Application of wastes requires assessment, approvals
X
--
X X X
DROP. The LDR program has basically mandated that hazardous wastes, including ignitables, must be treated before landfill. X KEEP. A reasonable approach. The rules fail to capture all high-threat wastes as "hazardous". X KEEP. Good protection at low cost.
KEEP. Simply requires policy-level approval to get into waste disposal business. X KEEP. Land application is high risk, in that any cleanup will involve large land areas.
1.4 Assessment of air emissions X X
1.4 Assessment of water discharges
XX
2 Policy for Employee,
XXX
Contractor, Community Safety
2.1 Health Surveillance and
XXX
Assessment
L,, REVISE: This policy as written has "past its time", but the Core Team has recommended new language/program to deal with the "residual risk" issue after MACT. REVISE: This policy as written has "past its time", but the Core Team has recommended new language/program to deal with the risk issues likely to emerge on a watershed basis in the future; this needs critical consideration.
i KEEP. These are reasonable principles that should guide our actions. Consider adding contractors to Commitment statement. KEEP, but more clearly focus health assessment language on workers workplace exposures.
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Sheetl
Compliance iResp. Care : Beyond Resp. Care
Pledge Program
Program Element
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Recommendation
2.2
23
2.4 & 3.4.9 2.5
Data Management, workplace materials and exposures Reviews and Guidance (safety audits, LP&EC reviews, compliance with policy/stds Spill Prevention
XX XXX
XX
Personnel Training and Security X
X
KEEP. A right to operate, defense and management necessity. Drop the reference to MARS. KEEP. A right to operate, defense and management necessity.
X KEEP, but REVISE to reflect the new 75% by year 2000 goal, as agreed to by the MLC. KEEP. A right to operate issue.
3 Policy for Process Safety/
XXX
Emergency Response
3.1 Process Development and
XXX
Design
3.2 Project Reviews
XXX
3.3 High Hazard Materials (HHM) X X
Program'
3.4 Operational Safety
XXX
Management (procedures,
training, contractors, MOC,
audits, investigations)
3.5 Emergency Response
XXX
5 Policy for Safety in Distribution X X X
KEEP. KEEP. Right to operate and management tool. KEEP. A right to operate issue. KEEP. A right to operate issue. KEEP. A right to operate issue.
KEEP. A right to operate issue. KEEP. Consider adding carriers/distributors to Commitment statement.
5.1 Incident Reduction (in distribution)
5.2 Safety Standards for Warehouses and Terminals
6 Policy/goals for groundwater and soil quality
XXX
KEEP, but edit out Ag references.
X X X KEEP. Reasonably needed to assure right to operate.
XX
KEEP. These are reasonable statements of the principles under which we must operate
Sheetl
Pledge Program
Program Element
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Recommendation
Groundwater Assessments at X X X
REVISE to reflect that this is a continuing proqram at acquired sites and at
Major/Contaminated Sites
sites that have issues; no longer a new initiative.
6.2 Groundwater Protection
X X X KEEP groundwater protection plans, facility design stipulations. Recommend
that we STRENGTHEN our position on impoundments except for post
treatment or stormwater storage.
6.3 Superfund Site Actions
XX
KEEP, these are reasonable actions that we are likely to take even without
this requirement, to minimize cost and maximize public acceptance.
_--
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Policy for Outside Processors
XX
KEEP.
7.1-7.2 Selection, Assessment and
XX
KEEP, this program was recently overhauled.
Approval of Outside Processors
9 Policy for ESH Reviews of
XXX
Capital Projects
9.3-9.5 Procedure for project reviews X X X
10 Policy for ESH Reviews of
XXX
Acquisitions and Divestitures
10.3-10.5 Procedure for A&D reviews
XXX
11 Policy on Compliance with Laws X X X
and Policies
12 Policy and Procedures on
Reproductive Hazards in the
Workplace
13 Policy and Procedures on Safe X X X
Handling of Carcinogens
14 Policy and Procedures on
XX
Contractor/Guest ESH
Standard
KEEP. Assures new projects are compliant, risk averse, protective of health and the environment. REVISE to reflect the new Chemicals nomenclature, organization. KEEP. An essential element for compliance, safety, health and financial Skoals. REVISE to reflect the new Chemicals organization. X KEEP, but revise the title, if kept, to focus on sites where the company does have operating control. Title is misleading, content of policy is not. X KEEP.
I^EEP. KEEP.
.
STLCOPCB4032785
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Sheetl
Pledge Program
Program Element
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Recommendation
16 17 New New
New
Policy and Procedures on Use X of Ozone Depleting Chemicals
X
Policy and Procedures on ESH X X X Auditing VPP Program; Achieve Star Status at all Sites Network to Implement Behavior Modification Safety Principles
-- ...ESH Compliance Management Systems
KEEP. This is a recent addition to the policy inventory, is probably more applicable to Chem than to LS. Not overly strenuous as written, but solid direction. KEEP. Update to new Chemicals nomenclature.
X ADOPT, with goal of all sites with Star status by 12/97.
X ADOPT, with goal of having programs in place by end of 1998.
X ADOPT, with goal of having all sites verified essentially compliant by end of 1999.
Filed as [Ityjcommitl .xls
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STLCOPCB4032786
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Sheetl
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II. Co mmitm<mt: Prod uct Stewardship
Pledge Program
Program Element
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Recommendation
4 4.1 4.2 4.3
15 New New New New
Policy for Product Stewardship . X X X
ESH Information and Risk
XXX
Characterization (re. products)
Risk Management System
XX
Principles and Key Elements X X X
(info for R&D, tollers, to/from
customers, suppliers)
Policy and Procedures on Use
of Animals in Research
Product Stewardship Code
X
Compliance
Review of Business Product
Porfolios
Product Stewardship Training
Program for R&D
Use of NPPD Process to Drive
Sustainability
KEEP. An evergreen statement.
X REVISE marginally to accommodate planned IT improvements on info
management. Toxicology Section assembly process can be revised.
KEEP. Still don't know all minor uses of all products in U.S. or Europe,
although excellent progress has been made in Canada.
KEEP and UPGRADE. Incorporate principles into NPPD process. Expand
"employee" feedback to be "stakeholder" feedback. Strengthen discipline in
assuring data transmittal to tollers.
.
X DROP. A much diminished issue in a Monsanto without pesticides,
pharmaceuticals.
ADOPT, with all "gaps" identified and closure plans developed and reviewed
by management by end of 1998
X ADOPT, with goal of screening all portfolios to identify sustainability
opportunities and threats by end of 1998.
X ADOPT, with pian to develop ESH/Product Development training to impact
product/process selections.
X ADOPT plan to evaluate opportunities with the NPPD process which has
integrated sustainability concepts into its evaluation.
Filed as [Ityrjcommit2.xls O m s:
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STLCOPCB4032787
Sheetl III. Commitment: Operations Open To Communities; Open Stakeholder Communications
Pledge Program
Program Element
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Recommendation
3.5.5 8
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New New
Communication of Potential Policy on Community Awareness at Mfg: Sites _ Community Involvement and Dialogue________________ Info, on Chemical Releases/ Incidents______ Annual ESH Progress Report Pursuit of Sustainability
New__ CERES New Telephone Access
x KEEP. x x KEEP. A right to operate need.
x x KEEP. Assures right to operate.
x x KEEP. Essential elements of a good community relations dialogue.
x x ADOPT goal to issue an annual progress report.
x ADOPT intent to actively seek opportunities to work collectively on global
sustainability, including in development of strategic philanthropy.
_
x ADOPT and execute plan to sign CERES principles. ______
x ADOPT and execute plan to establish "1-800" number for ESH/sustainability
calls.
Filed as [lty]commit3.xls
STLCOPCB4032788
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Sheetl IV. Commitment: Ec<>noimiciilly/ Environmentally Efficient Operations
Pledge Program
Program Element
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Recommendation
1 1.1 1.1 1.1 1.2 1.2 1.2
1.3 New
New
New
Policy for pollution prevention
XX
Statement: Toward Zero Effect;
XX
heirarchy of methods
70% Waste Reduction Target,
XX
future program for effects-
based target
Inventory of waste generation
X
Deepwell injection of Haz.
Waste and SARA 313
chemicals
Contingency Plan for Deepwell
Withdrawal
No new uses of Deepwells,
unless approved at policy level
Record of commercial waste
X
treatment, disposal
Process and environmental
X
efficiency in new processes and
projects
Target New Environmental X X
Efficiency Goals
Efficiency Review of Processes
X
X KEEP, integrate into Commitment statement. KEEP
NEED NEW pollution prevention program with goals, with emphasis on sustainability (see below).
KEEP X DROP. Replace with a robust pollution prevention program, with emphasis
on sustainability (see below).
X KEEP. Makes good sense to be ready for this eventuality.
X KEEP. Keeps pressure on deepwell sites to look for viable options.
X Keep, a must if we get called under Superfund.
X ADD a program element to assure review of process/project materials selection and utilization in project reviews.
X DEVELOP and ADOPT improved pollution prevention program based on ^ustainability principles, including focuses on: 1) lowering TRI releases as___ % of production 2) lowering deepwell losses as___ % of production 3) developing C02 emissions target by the end of 1995.
X ADOPT plan to complete efficiency/sustainability review of all processes for improvements, by end of 1997.
STLCOPCB4032789
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Sheetl
Pledge Program
Program Element
New Technology Development
New Business LRPs
New Waste Reutilization
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Recommendation
-X X ADOPT plan to evaluate technology partnerships for ESH needs on a continuing basis. X ADOPT plan to ESH/stewardship status and needs in LRPs for businesses.
X X ADOPT plan to use industry and regulatory contacts, TRI lists and Internet to develop list of potential wastes for recovery/sale and commit a small amount of research budget.
Filed as [ityfjcommit4.xls
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i Sheetl V. Act ve Employee Participation
Program Element
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Employee communications Annual award program used to track & reward performance Employee survey to determine attitudes and needs
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Recommendation
ADOPT with 9/98 target date. ADOPT...................................
ADOPT with 1998 target date.
Filed as [lty]commit5.xls
STLCOPCB4032791
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