When WME Media decided it was time to put its house in order, the process raised as many questions as it answered. Richard Collins reports.

Audits ain’t audits. This was WME’s first lesson when it set off to assess and address its environmental impacts. While there are templates, an environmental review is an organic process shaped by the goals and resources of the organisation, not a set of road rules everyone must follow. Even after drafting the environmental risk register, the document at the heart of the review, it becomes a living tool that management interprets, applies and updates.

WME approached Aaron Westwood of veteran environmental consultancy Graham A Brown & Associates. Like many environment managers, we had no direct in-house experience in this area. This presented the first hurdle – jargon. All the talk of “aspects” and “impacts”, Australian and international standards, life cycle analysis models and the defined requirements of environmental management systems was a little daunting.

It also meant rethinking some of our goals, a common reaction. Businesses decide to do an audit for a variety of reasons and often with loosely defined aims: reduce risk exposure; meet client demands; compliance; and content for sustainability reports. While every organisation may be different, the process is only flexible within defined parameters and based on the auditor’s experience.

Our first meeting with Aaron was crucial in determining the shape of the desired outcomes, what resources we would commit and what was achievable. For example, as a publisher we believed paper was likely to be the key environmental issue and expected to go deeply into its selection and impact assessment. So did we really just want a life cycle analysis of a few key business inputs? Or were we looking to establish a full, standards-compliant EMS? Or was a broad assessment of all our impacts and development of key management policies enough? We settled on the latter, a balance between available resources and our desire to lighten our impact.

Upstream impacts
The review begins with development of a basic Environmental Risk Register with 12 columns. Inputs and outputs which make up each of our “activities, products and services” are examined to determine our environmental footprint. For each of the 23 identified items we listed their potential environmental “aspects”, such as generation of waste paper or the plastic wrap used to protect and mail out the magazines. Most companies have far more.

For every aspect, we determined the “impact” or risk resulting from the aspect, such as contamination of waterways, addition to landfill or use of non-renewable resources. Some aspects may have more than one potential impact too, and this sparked lengthy discussions about how far back up the product life cycle we needed to go. For example, do we try to figure out the energy costs of collecting and transporting recycled paper, or the biodiversity impact of plantation forests?

“It depends on how much you can influence the impact,” said Aaron. “A risk register will typically look at end-of-life impacts but there is nothing to say you can’t have a control that impacts higher up the chain, such as a procurement policy. Organisations will generally capture upstream impacts after managing the existing risks however.”

Most WME impacts are indirectly through suppliers, so a column headed “Control or Influence?” was added to indicate whether WME had management responsibility for the aspect or was only able to influence it through a supplier management program.

Prioritising risks
So what were the results? Priorities were determined by their “significance” or level of environmental risk associated with the impact with existing controls in place. We based our methodology on accepted standards (AS/NZS 4360:2004 Risk Management), determining the likelihood of each risk occurring and the severity of the consequences if the controls failed, with a 1-5 ranking for each. Combined, these produce a risk rating from which we can determine management priority.

Assessment of risk is partly subjective and situation-specific and does not take account of complicating factors such as the value of consequences. Do you look at the global impact, the local or just the office environment? How severe is the impact of emissions, and is it more severe in urban areas than rural? Is the impact of disposal to landfill greater in Sydney than in Melbourne? Professional advice is invaluable here, as is the involvement of personnel responsible for managing the risks on a day-to-day basis.

The last columns headed “Controls” list the measures currently in place to manage each risk, and the potential policies to reduce the level of risk further. Generally, the types of management actions and their priority are determined by the level of risk.

Surprise findings
Columns can be added to the basic framework to tailor it to the particular business. Aaron suggested override columns that make “significant” any aspect governed by a legal requirement or of particular interest to our stakeholders, irrespective of the actual risk rating. Under the ISO 14001 standard, documented operating procedures are required for these aspects.

Some of Graham A Brown & Associates’ ISO 14001 certified clients have gone much further, adding columns detailing parameters such as regulatory requirements, areas for internal auditing and employee competency requirements.

The cut-off score for what WME would consider “significant” was set at 12, leaving the key impacts as use of paper and plastic wrap, distribution of magazines, and car and aeroplane use, this last one coming as a something of a surprise.

We’ll detail the key outcomes next month, including the supplier policy and program, but it has already seen us focus on the finer details of how WME Media runs. Aaron said this process usually does provide focus and a few surprises, and if nothing else, helps centralise operational information with regard to environmental controls. To date it has taken three of us six hours.

Full Environmental Risk Register at www.wme.com.au. Further resources can be found at the
www.grahamabrown.com.au (Free Downloads).