August 6, 2003
American Society of Safety Engineers (ASSE)
Sue Trebswether, Editor
1800 East Oakton Street
Des Plaines, IL 60018
ADDITIONAL COMMENTS ON THE SARBANNES-OXLEY ACT
FOR PROFESSIONAL SAFETY JOURNAL
Dear Ms. Trebswether:
Each of us have recently seen a great deal of information come out on the Sarbannes-Oxley Act of 2002 (Public Law 107-204) and how it impacts the SH&E profession. As Chairman of the Council on Practices and Standards (CoPS) Business of Safety Committee (BoSC), let me attest to how many members have expressed interest in this issue.
A statement was put together by the BoSC, reviewed/approved by CoPS and reviewed by appropriate counsel and Society staff. The BoSC has reached consensus that this is a significant issue for our profession. You can view the technical report prepared by the BoSC on the website at: http://www.asse.org/prac_spec_cops_issues13.htm
To all of you safety, health & environmental (SH&E) professionals, please take a moment and review this technical report carefully. This act has clear implications regarding SH&E professional conduct and reporting, as well as for CEOs and CFOs. In particular, it addresses the SH&E activities we should be proactive in performing and informing the company and its stakeholders.
If you do not already generate an SH&E annual report for your company officers, you should seriously consider adding that to your annual "to do" list. The company annual report should include such items as:
* Goals for the year, accomplishments, initiatives, budgets, success stories, performance awards, performance milestones, staffing, trends, etc.
* A summary of serious incidents and corrective actions taken and status
* A summary of all SH&E audits conducted throughout the year with corrective actions and status
* An environmental characterization of all properties owned or leased, and bought or sold by the company and their status.
* A benchmarking of your management system (or equivalent) across business units.
In addition to informing all company business units of your overall impact and benefit to the company bottom line, the annual report is a great marketing tool both internally and externally. Most importantly, it will be a document third party auditors will evaluate to ensure accountability of company officers overseeing SH&E.
My own personal belief is that those who lack the experience and knowledge in SH&E will likely look for those who are to oversee SH&E at the corporate level. This, I believe, will come to fruition due to the attendant risks of incorrect reporting and severe accountability when found not in compliance in this area. The final answer is, if you are overseeing SH&E and don't thoroughly understand it, with the attendant risks, you will be compelled to make sure you have someone on the corporate staff who does. If you don't, you may risk paying the price for incorrect reporting.
I look forward to the debate that may and should take place about this issue. If you would like to comment on this issue please feel free to contact the BoSC via our staff liaison Tim Fisher at Tfisher@ASSE.Org.
Mark D. Hansen, CSP, PE, CPE