EHS Management & Compliance
Protecting our people, our communities and the environment is fundamentally important to the way our company operates.
Our company strives every day to conduct business in a safe and environmentally responsible manner. We are committed to providing a safe and healthy workplace for our employees and to reducing the environmental impact of our operations around the world. We believe that promoting wellness for employees and respect for the environment is not just the lawful thing to do, it’s the right thing to do.
Our Environmental, Health and Safety (EHS) Management System is based on the “Plan, Do, Check, Act” model, which allows us to assess and continually improve our practices over time. The model is implemented globally through a set of interwoven business processes that span the corporation:
- Our planning process includes developing goals, objectives and metrics based on a review of our company’s performance, EHS programs, applicable regulations and external factors that may impact our business (PLAN)
- Activities are performed by using standards, guidelines and tools that are integrated into the EHS Management System and include specific expectations for sites and operating organizations (DO)
- Governance committees, from the executive-level EHS Council through site-based compliance committees, review business unit performance and progress against objectives throughout the year (CHECK)
- Corrective actions and continuous-improvement initiatives are established to resolve EHS concerns that have surfaced during periodic assessments, audits and routine surveillance of the regulatory landscape (ACT)
Our corporate EHS management system is generally aligned with the requirements of the International Standards Organization (ISO), but we do not pursue certification under the Environmental (ISO 14001) or Safety (ISO 45001) frameworks at the global level. Some of our facilities have individually achieved ISO 14001 certification to meet customer requirements.
In addition to complying with all applicable country, regional and local safety and environmental laws, we strive for EHS performance that is among the best in the pharmaceutical industry.
We also adhere to the following key operating principles:
- Maintain a safe and healthy working environment for all employees, contractors and guests
- Foster a culture of EHS excellence that is built on science, integrity, accountability, personal responsibility, collaboration and active employee participation
- Seek to continuously improve our EHS systems, processes and standards
- Minimize our impact on the environment by identifying and implementing approaches to reduce the resources we use during the design, development and manufacture of our products
- Understand the potential hazards associated with our products and take action to minimize any potential risks or adverse impacts
- Promote EHS excellence in our supply chain by entering into business relationships with partners that share our commitment to responsible EHS stewardship
Training is critical to building worldwide employee competencies that will improve compliance, reduce risks and drive continuous performance improvement.
We have a global standard that defines the EHS training expectations for employees in three categories:
- Manager training covers specific management responsibilities with regard to safety and environmental compliance and promoting a “safety first” culture
- EHS professional training is designed to expand technical expertise and improve our EHS capabilities around the world
- Employee training covers the specific information our employees need to perform their jobs in a safe and environmentally compliant manner, focusing on hazards and control measures they encounter on the job
Site EHS professionals complete an assessment of the activities performed at their sites and ensure that relevant topics are included in their site training plans. They develop employee training curricula to comply with internal and regulatory training requirements. These training programs are reviewed periodically to ensure that they remain current. Our EHS training program materials are available in both instructor-led and e-learning formats. We also conduct periodic Web-based seminars to inform EHS professionals of changes in regulations, standards and company practices.
A mandatory course for all senior company leaders highlights the importance of EHS to the business, the critical role senior leaders play in EHS performance, and the specific actions our leaders can take to drive their areas of accountability toward EHS excellence.
Our commitment to the environment and employee health and safety begins with the company’s Executive Committee, which has established the corporate Environmental, Health & Safety (EHS) Council.
The EHS Council is composed of senior-level executives representing all business units, and is responsible for overall EHS governance, as well as for leading and driving enterprise-wide excellence in EHS management and performance.
The Council’s responsibilities include:
- Establishing EHS strategy, policy and standards
- Providing companywide oversight of environmental and employee safety issues, risk mitigation and control strategies
- Monitoring performance, establishing continuous-improvement targets, and recognizing and promoting EHS excellence
- Allocating resources and/or sponsoring projects to address specific EHS concerns
An EHS Standards Committee has been chartered by the Council to provide stewardship over the Standards and enable business engagement in the development of new or revised Standards. Each area of the business is responsible for executing against the Standards, contributing to the development of programs, supporting internal audits and communicating significant EHS events. Divisional EHS compliance committees have also been established to provide governance on the implementation of the Standards, and to manage, execute and resolve EHS issues as they arise.
The vice president (VP) of global safety and the environment (GSE) is responsible for communicating to the Board of Directors, the Executive Committee and the EHS Council regarding progress on goals, objectives and metrics, as well as other material issues. The VP of GSE partners with business leaders to establish long- and short-term goals and performance metrics to drive EHS excellence.
Safety and environmental performance targets are included in divisional management objectives. In addition, all employees are eligible for special recognition for innovative ideas and projects related to improving EHS aspects of our operations.
Learn more about our corporate governance efforts.
Our corporate EHS organization is responsible for:
- Developing corporate policies, procedures, guidelines, standards, tools and programs to set expectations and to support EHS compliance
- Providing technical and regulatory support to site-based EHS staff and operating organizations
- Managing and implementing an internal audit program targeted at understanding the current state of compliance and identifying potential issues
- Tracking and communicating internal and external trends that should be addressed
- Anticipating, tracking and commenting on new regulations affecting our business and, where appropriate, developing plans to address them
- Tracking EHS performance of sites, divisions and the company as a whole, and communicating performance versus targets
Our site-based safety and environmental professionals around the world support the EHS needs of their business areas, which include manufacturing, research operations, sales and administrative activities, by:
- Ensuring that line management fully understands EHS requirements, including applicable regulations, permit requirements and company EHS Standards
- Establishing, assessing and improving programs
- Providing regulatory and technical support to employees and the operating areas
- Routinely assessing performance against our company standards, regulatory requirements and performance targets
- Acting as the primary liaison with local regulators and inspectors
- Investigating incidents and near-miss events to identify root causes and developing corrective and preventive actions to prevent recurrence
We have a detailed and rigorous EHS audit program.
Our global corporate EHS audit program is one way in which we identify and resolve compliance and performance issues within the company.
- Our audit leaders are full-time professional EHS auditors with extensive experience in auditing a broad range of EHS programs applicable to the company. The individual audit teams consist of EHS professionals with extensive site and subject-matter expertise. In many cases, particularly outside of the United States, our internal auditors work with independent consultants who have regulatory expertise in the laws of the host country.
- All audit findings are addressed through the development of corrective and preventive action plans, which are reviewed, approved by the audit leader and regional EHS leader, and tracked to completion.
- Findings from our audit program are communicated to appropriate parts of the organization so that learnings may be shared, and actions can be taken.
- Audit performance and key program metrics are reviewed as part of our governance process.
We use multiple factors to determine the audit frequency for our facilities, including facility size, operational complexity, compliance status and performance history. Our most complex operations are audited every year, and all manufacturing and research operations are audited at least every two years. Less complex facilities, such as sales and business offices are audited less frequently. In 2018, we performed 48 corporate EHS audits of our facilities, covering 69 percent of our manufacturing and research locations and involving 718 auditor days of onsite review activities.
An internal Quality Assurance Review of the EHS Auditing program was conducted in 2018 by Corporate Audit and Assurance Services. As a result of this internal review, the EHS auditing program was rated “Effective,” with controls and practices deemed to be in line with Company requirements and expectations. These results were consistent with the third-party review of our program in 2017.
In addition to our corporate EHS audit program, our sites regularly perform self-inspections, and annually complete self-assessments of selected regulatory requirements and company standards, with all programs being evaluated at least once every three years.
Environmental management practices have evolved significantly over the past 30 years.
With research and manufacturing operations dating back more than 100 years, some of our facilities operated at a time when there were few regulations and little understanding of good environmental practices. Because our company has responsibility for remediation of these sites, we have launched investigations, developed science-based remediation plans and implemented cleanup projects to protect the health and safety of our neighbors, communities, employees and the environment, and comply with all applicable requirements.
Over time, we have acquired properties and manufacturing facilities that may not have been subject to the same EHS management standards that we have in place today. We are also investigating and remediating those properties where necessary.
We spent $15.9 million in 2018 for remediation and environmental liabilities, including those at formerly owned and operated sites. Our company has an environmental liability reserve of approximately $70 million to fund the continued remediation of these sites into the future. In addition, we are a potentially responsible party at 18 multi-party Superfund sites in the U.S.
Our centralized EHS information system allows us to collect, manage, learn from and share our safety and environmental performance data more efficiently.
We collect and analyze data in both leading and lagging metrics to look for potential trends and identify opportunities that can help drive performance improvement. We continuously explore new ways to learn from and report on our performance.
Notices of violations, fines and settlements
We report all forms of EHS compliance notices using the term Notices of Violation (NOVs), which includes citations, letters of warning and notices of noncompliance from environmental and safety-focused regulatory agencies.
In 2018, we had 184 EHS-related regulatory agency inspections of our facilities around the world. We received one safety-related and six environmental-related NOVs and paid no fines in 2018.
|Notices of Violations (NOVs) & Citations||2014||2015||2016||2017||2018|
Significant environmental events
A “significant environmental event” is defined as an environmental release that results in environmental harm to humans, aquatic organisms or wildlife, or any environmental release that requires reporting to the U.S. Securities and Exchange Commission. We experienced no significant environmental events in 2018.
|Environmental fines paid||$81,600||$92,270||$33,906||$0||$0|
|Number of environmental fines||4||6||2||0||0|
|Safety fines paid||$1,000||$0||$0||$0||$0|
|Number of safety fines||1||0||0||0||0|