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Environmental Risks Associated With Business Disruption

23 April 2020
Planning for the unknown is a challenging task. An infamous explanation of this type of challenge was voiced in 2002 by then US Secretary of State for defense, Donald Rumsfeld. 

The context of the following quote was during a press briefing in a response to a journalist question related to the Iraq war:

“Reports that say that something hasn’t happened are always interesting to me, because as we know, there are known knowns; there are things we know we know. We also know there are known unknowns; that is to say we know there are some things we do not know.”

“But there are also unknown unknowns – the ones we don’t know we don’t know. And if one looks throughout the history of our country and other free countries, it is the latter category that tend to be the difficult ones.”

To some people, the immediate reaction to this quote, was humorous. Upon reflection it is actually quite a serious statement and one that anyone with decision making responsibilities should opine.

How do we apply this statement to an Environmental Management System (EMS)? Considering the internationally recognized ISO 14001 standard, there is a section with requirements for operational control and planning. One of the requirements states:

 “The organization shall control planned changes and review the consequences of unintended changes, taking action to mitigate any adverse effects, as necessary”.

When I audit a client’s management system, this requirement sometimes evokes an exasperated response such as, “how can we possibly plan a response for something that is unknown or unintended?” Considering Donald Rumsfeld’s comments, how have you considered your environmental risks and opportunities according to the three categories outlined by Mr. Rumsfeld? Let us look to the frame work requirements of ISO 14001 for guidance.

When considering how to plan according to the risks and opportunities, an organization must first define and understand its context, a requirement within Section 4 of the ISO 14001 standard. The exercise to define an organizations context would include all relevant things which are impacted by the existence of your organization and those things that affect the ability of the organization to operate such as, culture, regulations, geography, and geopolitics.

Section 6 of the ISO 14001 sets the framework for planning according to the context of your organization and the risks and opportunities within that context. This framework is not solely focused on environmental conditions. Planning also includes consideration of lifecycles, technological options, financial, operational and business requirements.

How does this framework apply to business disruption and unknown unknowns? Let’s consider for a moment the risks associated with a large disruption to continuity; such as a hurricane, Ice storm, conflict or pandemic. If you have chemical waste storage, what are the effects of an event to the waste storage possess regarding regulations? What about storage capability if infrastructure disruption doesn’t allow for timely offsite transportation of waste or the facility you use currently is unable to be resourced?

What about competent staff availability? Using incompetent staff, while well intentioned, could quickly lead to a safety issue or legal issues with manifest signatures. Are there product expiration dates which will add to waste streams because of lower production or spoilage due to the inability maintain storage temperatures? What would this do to your generator status?

What unknown condition can be imagined that would cause emergency response measures to become overwhelmed? Assuming that your organization has initially planned for risk and opportunity conditions, when was the last time these were effectively reviewed to adjust to changes since the last evaluation?

Business as usual is a wonderful thing. How well an organization plans for abnormal operating conditions can be “business as usual” too. Is your environmental management system robust enough to operate normally under abnormal conditions? Utilizing the ISO 14001 standard to its full intent could be an essential tool and opportunity to reduce the operational risks associated with the adverse effects of unknown unknowns.
Author: Randy Pittman, Environmental Health and Safety Business Unit Manager and a Lead Auditor at NQA USA.