CSG: Safe Environment

Posted on http://www.csg.co.uk/blog on May 21st 2019

https://www.csg.co.uk/blog/safe-environment

As you probably know, we take our Health & Safety responsibilities very safely, here at CSG.  Last April, we held our inaugural ‘Health & Safety Week’, something we’ve already planned to repeat this year.  As part of our developing focus, we’ve decided to turn this very broad topic into four more clearly-defined categories: Safe Processes, Safe Equipment, Safe Environment and Safe People.  Continuing the series, we’ll investigate what is covered by the Safe Environment element of our policy.

Safe Environment

Ensuring safe conduct of large numbers of people in an area where lots of hazardous things happen every day is a demanding task.  It’s an obligation in which everything has to happen correctly, all the time, to ensure success – conversely, only take a few transgressions can result in a serious incident.  When the stakes are this high, even being almost perfect just isn’t good enough.

Much of the risks we manage can be mitigated by providing clarity about the ways we expect people to behave, in the guise of training and rules.  As comprehensive and as sophisticated as they are, ultimately, they’ll always require each individual’s compliance to have the desired effect.  What if, for whatever reason, those control measures are ignored or overlooked, even accidentally?  What else can be done to convey vital information quickly and effectively?

One answer is to control our environment, all the areas in which we operate, to reinforce the requirements and principles, clearly and consistently, that underpin our Health & Safety policy.  From ‘softer’ measures to achieve this control, like signage all to ‘harder’ measures like restricted access areas, essential safe practice can be governed by the organisation of the very place that requires it.

Sarah Taylor, CSG’s Compliance Manager describes the scale of the issue:

“This consideration is both complicated and made more necessary by the fact that we have such a wide variety of workplaces to cover, from offices to laboratories to workshops, as well as plant areas and the waste handling areas themselves.  Each type of location will have its own hazards and procedures to ensure safe working where they exist.”

You might conclude that the challenge here is similar to safe road use – passing a driving test may give you the ability to drive on any road but it gives you little or no insight about the various hazards and limits that exist on every motorway, mountain pass or one-way system in the country.  Only by a combination of your knowledge of the rules, together with a consistent approach to information of the requirements and restrictions specific to every area, can safe road use be assured.  As a driver, you must learn the wide variety of road signs because you’re expected to obey them.  In return, you can expect signage to be present at each and every location in which those rules apply.  Similarly, physical features such as speed bumps and barriers can enforce restrictions beyond simply informing users of the rules.

In environments such as those which CSG operate, the process of restriction can go much further than public roads can.  If you’re determined to ride a bicycle on the motorway, there’s nothing to physically stop you – the Police will soon find you and advise you that you have broken the law in doing so, but realistically, that system can only be run on a ‘first failure’ basis – with suitable deterrents.  At our sites, considerations of public access don’t apply and, crucially, ‘first failure’ isn’t an option.  This means that we can design our layouts and add manned checkpoints or doors operated by keycards in order to stop even those who may deliberately wish to ignore the restrictions.

As with other aspects of CSG’s Health & Safety policies, there is an unwillingness to confine the scope simply to that which is expected of us.  We believe there should be expectations above and beyond the obvious and necessary.  This year, there’s an emphasis on ways to replicate the safe working measures that employees can expect at CSG sites to be applied when they’re working off-site, as Sarah explains:

“On any given day, so many of our people will be working at locations not operated by CSG, and, of course, driving from one site to another.  We’re keen to ensure that we look after the health and safety of these colleagues as much as any other.

“It’s less easy because, unlike at our own sites, we do not have ultimate control of the environments they will face – but that doesn’t mean we shouldn’t try to exercise our influence, where we can.  We encourage any of our colleagues working off-site to report any concerns and ensure we raise them with the local operator, as encouragingly as possible.  Generally, companies do try to avoid being thought as ‘unsafe’ so where measures are suggested, they tend to be addressed in good faith.  We may only be able to influence rather than control but the value of influence is often under-rated.  As with other areas of our Health & Safety practice, we find time and again that avoiding a culture of blame is a very important way to make a real difference.”

As in other areas, that word ‘culture’ appears – and seems to be key to success.  We may all presume that only an iron grip of rule enforcement offers the surest way to achieve total compliance but there are softer benefits that a clearly-controlled environment can bring.

“It’s just another way to be clear with people, to make the point that this all stuff really matters – and that your adherence is vital to its success.  We hold a log of unsafe acts in order to understand how each instance could have been avoided and to monitor improvements once we’ve addressed each issue and we consistently find it’s much easier to effect change when we can prove to people the need to ‘buy-in’ to what we’re trying to achieve.  The more that people want to do that, the easier it is to ensure that everyone makes the right decisions.”

CSG: Making Sustainability Count

“Knowledge is power”. “Data is value”. “If you can’t monitor it, don’t do it”. We’re probably all familiar with these rather trite sayings because aspiring managers everywhere love to sprinkle them into their meetings and briefings. It’s tempting to treat them as a fashionable irrelevance, like more notorious examples such as “blue-sky thinking”. However, just because a belief in number-crunching is so closely associated with management-speak, it doesn’t mean it’s meaningless. Far from it; unlike the more cringe-worthy sayings like “sweating the asset”, there’s lots to be said for, er, sweating the data asset – so to speak…

CSG is one of those businesses for whom more data is better than less. Financial performance, tendering capability, regulatory compliance and many other aspects of the business are all governed by clear, accurate, day-to-day data-gathering. Crucially, in order to operate with distinction in the waste sector, we also need to be able to practice what we often preach – a commitment to environmental excellence – and that means we need to be able to point to some impressively green statistics.

In 2015, we signed up to the Government’s Energy Saving Opportunities Scheme (ESOS), having met the quite stringent criteria, to apply.   The following year, we joined the Logistics Carbon Reduction Scheme (LCRS). Both initiatives require us to manage and reduce our carbon impact and demonstrate more efficient ways of doing business. In order to start to do that, first, you need to know what your starting point is, which means – you’ve guessed it – closely monitoring our energy usage.

The font of much of our statistical knowledge is Antony Gerken, our Permitting and Compliance Manager. It’s Antony who ensures that our many and varied accreditations are attained – and then retained – amid ever-tightening regulations. When the time comes to renew an ISO certificate or add another to our long list of accreditations, Antony’s our go-to guy to get the job done!

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Imagine the fuel required to power this truck to drive around the world twenty times.  Photo: CSG

In order to achieve better carbon efficiency, several years ago, we took the decision to refresh a large proportion of our fleet of lorries, a process that came to the end of its cycle last year. Now, with enough time having passed to generate enough usage statistics, Antony is able to quantify the effectiveness of our fleet investments of the last few years. A combination of newer, more efficient trucks, the ability to monitor inefficient driving and computerised job schedules, digitally communicated to drivers, have all promised more efficient mileage and less time travelled between jobs. Antony describes his most impressive finding:

“We usually average between 8-10 miles per gallon for our tanker fleet. In 2017 we hit an average mpg of 10.389, which is a significant improvement on 2016. If you assume we did the same mileage in 2016 and 2017, the increased efficiency works out at around 200,000 fewer litres used in 2017.”

As we all know, the standard unit of measurement for lots of liquid is the Olympic-sized swimming pool (2.5 million litres). 200,000 litres of fuel isn’t nearly enough to fill it, it’s about one-twelfth of the volume. You could try to visualise a depth of 16cm of diesel sloshing around in there but it may be more helpful to think of it this way: an average family car being driven in a way that requires it to be filled once a week uses around 2,800 litres a year. Our diesel saving alone in 2017 would have been enough to fuel over 70 such cars for a full year – the equivalent of a large housing estate or even a whole village’s annual use!

Another way to look at it would be to say that it’s the amount of fuel our more efficient fleet now requires to travel an extra 500,000 miles – the same as fuelling 20 CSG trucks to travel around the world!

In addition to the reduction of fuel being consumed, less diesel in also means fewer emissions being released. Antony calculates this figure to be 528 tonnes of CO2. Again, this isn’t an easy thing to visualise but there are ways to understand what that might be equivalent to, thanks to websites like yousustain.com. YouSustain suggest that the CO2 reductions we made through our fleet in 2017 are equivalent to the emissions of 104 cars for a whole year. Or 40 houses. Or, if you’re feeling adventurous, one whole 747 flying from London to New York – and back.

Of course, while environmental benefits are their own virtue, let’s not forget the fact that using less fuel costs CSG less money. The more financially efficient our operation is, the more competitive our prices can be. As is most often the case, if the environment gains as a result of someone saving money, it tends to happen more quickly and, as savings are there to be passed on, everyone can gain from the initiative.

As you can imagine, the quest for greater sustainability and better efficiency won’t stop here – to many people, the challenges of environmental responsibility have barely begun – but we believe it’s an important step and one that demonstrates our credibility to adopt the most fundamental principles of the Waste Hierarchy. In operating more efficiently, we’re preventing the consumption (and emission) of a significant amount fossil fuel. That’s got to be something worth “running up the flagpole”!

CSG: Who Will Watch the Watchers? The Case for Internal Audit

Posted on www.csg.co.uk/blog on January 29th 2018

https://www.csg.co.uk/blog/will-watch-watchers-case-internal-audit

“Quis custodiet ipsos custodes?” wrote the Roman satirist Juvenal around the turn of the 2nd century, raising questions of the capability of those in authority to discharge their duties responsibly. It’s a question that for the almost two thousand years since, civilisations have grappled with, resulting in the notion of auditing – to ensure that others can see that responsibilities are being met, as they should be.

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What happens when the watchers aren’t being watched?  Photo: Paul Bentham

Auditing and compliance are terms that every business has had to embrace more fully over many years, with ever-stronger obligations in areas of employment law, health and safety and day-to-day environmental standards. Beyond those more mainstream areas, a company like CSG, operating within a tightly-regulated arena such as waste processing and hazardous chemicals, you can imagine the sheer volume of regulation (and the consequences of getting it wrong) can be mind-boggling.

Of course, as a large, reputable company with many years’ experience in the field, this isn’t quite as daunting as it sounds – very many systems, processes and job roles have evolved over time to enable the management of the multitude of technical and bureaucratic requirements required of us. For the last ten years, though, we’ve felt it necessary to create our own extra layer of applying checks and balances, in order better to understand the way we continue to work within a constantly-changing regulatory landscape and, of course, to minimise risk.

That layer is the IAG, our Internal Audit Group, a committee of several Senior Managers and Directors who meet every two months and report to the CSG Board on all areas where compliance with regulations is a necessary requirement. Central to that mission is CSG’s Permitting & Compliance Manager Antony Gerken.

“The IAG came about as a result of our drive to gain ISO accreditation”, Antony explains. “From that initial requirement, it was clear that best practice involved learning from mishaps made by other people – to prevent issues from happening, rather than cure those that have happened.”

It is a sign of CSG’s stability and competence that most of the matters the IAG oversees are generally delegated back the team directly involved – it means the IAG’s principal role is an advisory one, where consultation from within CSG is sought and given.

“The very existence of the group is a means to encouraging the culture of every part of the company to continually accept and work better within our regulatory parameters”, adds Antony. “We’ve found that simply by raising the internal profile of the IAG within CSG, all the external audits we are regularly subjected to have become much smoother.”

The ‘box-ticking’ nature of ensuring compliance, especially with the more technical, seemingly less urgent areas of ‘red tape’, like Financial Compliance, gives the impression that this is very dry area of operation, suited to diligent bureaucrats with little need to apply ‘real-world’ understanding of the rules, like the Vogons of Douglas Adams’ ‘The Hitch-hiker’s Guide to the Galaxy’ – but that rather harsh stereotype falls down when you hear why it’s of interest to the IAG.

“Financial compliance sounds dull but it can often be the opposite: for example, one of our chief requirements is to be seen always to be working within the auspices of anti-bribery and anti-[money]-laundering laws”, Antony explains before adding, with a knowing nod, “which is especially important a consideration in certain other countries”, neatly making the point that, where compliance is required, the very nature of the exercise is to guard against problems and abuses that the rest of us, naively, would barely consider.

There are other advantages to all this watching. On a very basic level, having a broad range of experienced professionals to assess operational processes, bringing their collective experience to bear, means the remit goes beyond mere compliance. Inevitably, it leads to suggestions that make processes quicker or easier and therefore more efficient. Many times, real efficiency savings have occurred simply because a process has been more effectively scrutinised.

There’s also the secondary benefit of being better able to deal with upcoming rule changes from bodies such as the Environmental Agency, which is this: being seen to be better able to predict and respond to rules that affect the industry makes CSG stand out from its competitors. In other words, just being known to be more diligent is its own virtue, offering us a commercial advantage.

The nature of auditing is about understanding the fine detail, the micro-level of day-to-day matters but there’s one macro-level looming uncertainty that threatens to change so many areas of compliance that it’s already occupying much of the IAG’s thoughts – the expected impact of Britain’s impending exit from the European Union. It threatens to be a subject so wide-ranging, it will undoubtedly require its own blogpost, possibly several, and it’s still an area that offers so many unanswered questions.

Juvenal’s words are most commonly associated with the need to apply visibility to those in power. In order for the IAG’s questions about compliance in the world after Brexit to become answered, we’ll all have to watch a different set of watchers…