Well, by now, everyone has heard more than enough about Edward Snowden and the leaking of top-secret NSA information. As EHS auditors what can we learn from this type of incident? Here’s five things that come to mind:
- If you say it’s confidential, it’s probably not or won’t be for long. We, as humans, have an incredibly bad habit of not being able to keep a secret. As you probably remember when you were a child, your friend or you saying “You want to know a secret?” to each other. People love to have the feeling that they have unique knowledge that no one else has. So, unless you take away everyone’s cell phone and access to the internet, and then sequester them out to a remote area of the desert, plan on information getting out or keep it to yourself.
- Assume that someone is always listening. When the news broke about the NSA’s monitoring practices, I wasn’t surprised at all. In fact, I was already expecting it. As someone who is very technology aware, I understood that the ability to intercept data is not all that difficult, unless you are using a high-level of data encryption. Assume that every cell phone call and every email is being monitored. Better yet, do no wrong, don’t say bad things about others, play nice, and you will be fine.
- Dissemination of critical information must be controlled. Throughout the year, I perform numerous EHS audits and potent compound safety audits of pharmaceutical manufacturing facilities. In most cases, a closing conference is conducted at the end of the audit to review critical findings. This closing conference typically includes a presentation. Several good practices to protect information should be taken. These include: a) don’t distribute the information electronically ahead of the meeting; b) mark hardcopies “draft” and “confidential;” c) if you must use handouts during the meeting, collect them afterwards and before anyone leaves the room; and d) ideally, bound and numbered draft reports should be distributed for handwritten comments, and then collected at the end of the review period. Draft reports should be shredded once the final report is completed. Control the information and know who has possession of it. Once the final report has been issued, corrective actions should be promptly implemented. EHS software for tracking routine compliance tasks and corrective actions is readily available. Use these so you don’t have to chase down loose paperwork and make sure that corrective actions don’t fall through the cracks.
- Leaked information travels fast. As we saw from the Snowden case, once information gets out it can spread extremely rapidly and the media will be knocking on your door to get a story. Make sure that everyone on your team knows who is allowed to issue statements to the media, and who the media point contact is for the facility. This should be part of your orientation to new employees. Unfortunately, when severe accidents or environmental incidents happen, the media will be there quickly. Be prepared.
- You can run, but you can not hide. Well, unfortunately, if it’s you spilling the beans or involved in wrongdoing, you will be found. I remember numerous years ago, an acquaintance of mine for a different company, tried to cover-up an environmental permit reporting error. While not privy to all the details, it was discovered by his own company during a routine review and the EHS manager was terminated. The company then used the self-disclosure, environmental audit policy to report the violation to the State regulatory agency. After an investigation, charges were brought against the former EHS manager. As your mother always said, “Trying to cover up wrongdoing is always twice as bad as fessing up to it.” Understand your state’s self-disclosure and audit policy. Develop a rapport with your company’s legal counsel.
As EHS auditors we are tasked with upholding the high ground of ethical behavior. If you get into a dilemma, it’s best to follow your internal reporting processes for guidance. I’m sure they are many of you that have comments or opinions about this blog post. I would enjoy hearing them.