EHS Management System Integration
Bristol-Myers Squibb’s Environment, Health and Safety management system evolves in response to new scientific, technical and public policy information and through an ongoing dialogue with our employees, shareholders, customers and suppliers.
The key components are as follows:
Mission and Commitment
These are fundamental elements of our corporate culture. They set forth our concern for the interests and expectations of our employees, shareholders, customers, suppliers, the communities and countries where we do business, and the world in which we live. Among other things, Our Commitment is a formal commitment to conscientious citizenship. It supports environmental progress, a safe work environment, and policies and practices that fully embody the responsibility, integrity, and decency required of free enterprise.
Accountability and Organization
The Board Committee on Directors and Corporate Governance (CDCG) has responsibility for oversight of social and public policy. The CDCG members are all independent directors. The CDCG charter enumerates the responsibility as considering matters relating to corporate social responsibility and public policy as a global corporate citizen. Sustainability strategy is included within this scope. The CDCG determines the qualifications and expertise for Board membership and oversees performance.
Sustainability and its obligations are visible within the organization. The Vice President, Environment, Health, Safety and Sustainability reports to the Senior Vice President, General Counsel and Corporate Secretary, who reports to the CEO. Business unit presidents are held accountable for implementation of Our Commitment and EHS Policy within their units. Sustainability is integrated into the different functions and operations. A senior level cross-functional Sustainability Council was established in 2009 to drive alignment and integration of current and emerging strategic sustainability priorities.
The sustainability performance of the Company is reflected in the company’s annual economic, social and environmental reporting. Economic performance is covered in the Bristol-Myers Squibb Annual Report. Progress against the 2010 Sustainability Goals including detailed environmental metrics has been communicated companywide and to external stakeholders each year through the Bristol-Myers Squibb Sustainability web site. Progress against our Sustainability 2015 Goals will also be reported annually. Social performance is also covered in the Foundation Annual Report. The Vice President, Environment, Health, Safety and Sustainability meets with the Board of Directors to review performance and strategy on Sustainability issues as requested by the Board.
Capital Engineering Projects
Capital engineering projects for new processes, products, and facilities that may affect the environment or employee health and safety must be reviewed and endorsed by the facility EHS coordinator. The review must address the following, where applicable:
- permitted environmental releases
- sudden environmental releases (such as spills and explosions)
- hazardous and nonhazardous waste generation, storage and disposal
- disposal of raw materials, intermediates and final products
- health and safety risks to employees
- energy consumption
Requests for projects involving new products or packaging must include an evaluation of impacts on the environment.
Contract Manufacturers and Suppliers Guidelines
Under guidelines relating to contract manufacturers and suppliers, EHS evaluations of the facilities and operating practices of contract manufacturers and selected suppliers are conducted. The guidelines address topics such as: chemical storage and handling practices; waste storage, handling and disposal practices at sites; permits; emergency preparedness and response; employee exposure; regulatory compliance history; and financial position.
Corporate Audit Process
Performing comprehensive, rigorous Environment, Health, and Safety (EHS) audits is key to ensuring that we maintain and continuously improve a compliant, effective, safe and healthy workplace. EHS audits are designed to verify consistency of business operations with internal and external technical EHS and transportation requirements and to assess the adequacy of management systems in place at the company’s operations to support on-going compliance. Corporate, business unit and facility management use the results of the audits to maintain and continuously improve EHS performance companywide.
All manufacturing and research and development facilities, plus key distribution and office locations, are evaluated. The frequency of audits at BMS locations are based on business risk and on the maturity of the facility’s EHS management systems. Audits are scheduled annually for each affected facility and typically range from 18 to 48 months. After EHS Audits are conducted, corrective and preventive action plans are required to be developed by the facility and are actively monitored by the lead evaluator to closure.
The EHS audit function, within the Global Environmental, Health, Safety and Sustainability Department, has the responsibility to plan and conduct the audits, train and select team auditors, report audit results to management and monitor action plans through closure.
Bristol-Myers Squibb provides consumers, commercial customers and distributors with information regarding the safe use, transportation, storage and disposal of our products. The vast majority of our products relate to health care, the labeling of which is strictly regulated by various governments to ensure safe use. We follow the highest standards of labeling and product safety information for our health care products. The company also has systems for tracking consumer comments and adverse reactions to our products. Bristol-Myers Squibb then uses this information to modify product formulations, labeling and safety data sheets, as appropriate.
Bristol-Myers Squibb employees interact with health care professionals about products, medical research and patient health care on a daily basis. When it comes to our interactions with health care providers, we are committed to following the highest ethical standards.
Our drug promotion is guided by Our Commitment and guidelines set forth by organizations, such as the U.S. Food and Drug Administration, the Office of Inspector General and the Pharmaceutical Research and Manufacturers of America (PhRMA) association.
In July 2008, PhRMA announced plans to strengthen its “Code on Interactions with Healthcare Professionals.” A few of the key modifications to the code include: rules prohibiting the distribution of non-educational items, such as pens and mugs; clarification of provisions regarding educational materials; and guidelines for providing meals to health care professionals. Bristol-Myers Squibb fully endorses the modified code and abides by its recommendations.
Emergency Preparedness Guideline
All facilities must have comprehensive emergency preparedness programs in place that include: risk and hazard identification and assessment; emergency response, reporting and cleanup plans; and employee training. Facilities develop plans in cooperation with local emergency response agencies, such as police, fire and public health departments. Emergency preparedness drills are conducted at least annually and involve local emergency response entities whenever practicable. For more information about our facilities, refer to our facility section.
Employee awareness and training are at the core of Bristol-Myers Squibb's goal to be a leader in EHS management. Bristol-Myers Squibb provides guidelines for training both new and experienced employees. In addition, facility environmental coordinators and other full-time EHS professionals must complete, at company expense, annual EHS training related to their job assignments. Other company education initiatives include corporate and divisional intranet web sites; employee publications; functional and cross-functional group meetings; management awareness training; and topic-specific training and manuals.
Energy Management Program
A position of Director, Global Energy Services has been established with worldwide responsibility. An energy management program is maintained and updated based on the characteristics of specific operational situations. The Corporate Environment, Health, Safety and Sustainability Department reviews this program annually.
The program objectives are supported by a number of other company initiatives that require consideration of energy issues, including our EHS policy, acquisition due diligence, capital appropriation request review process and product life cycle reviews. As a result, our facilities are making greater use of state-of-the-art, energy-efficient technologies. For more information about our energy management programs see the environmental performance section of this website.
Bristol-Myers Squibb has engineering design standards and supporting specifications that are applicable to the design and implementation stages of a project. The standards allow the company’s engineering community to design and implement engineering projects that are mindful of sustainable development and are closely aligned with our Sustainability 2015 Goals. Examples of the standards include architectural, mechanical, environmental impact control, product select ion, roofing and painting guidelines. In addition to the company’s Sustainability 2015 Goals, the standards are based upon the LEED (Leadership in Energy and Environmental Design) standards developed by the U.S. Green Building Council.
Environment, Health and Safety Directives
The directives contain detailed information for Bristol-Myers Squibb's facilities and functional business areas. They address our EHS Management System and form the basis of Bristol-Myers Squibb’s EHS requirements worldwide. The directives may exceed local regulations.
Environment, Health and Safety Policy
Our Environment, Health and Safety policy sets forth our commitment to conduct our business in a safe and environmentally sustainable manner. This policy was approved and signed by Lamberto Andreotti, Chief Executive Officer on August 4, 2010.
Information Management Systems
Computer-based information management systems enable our company to maximize the effectiveness, productivity and value of our EHS program. Information management systems help us to pursue our goals of sustainable development and sustainable competitive advantage. Bristol-Myers Squibb has in place several computer-based information management systems, an operating results tracking system and several EHS intranet sites, including a Go Green site for employee awareness and suggestions. Numerous programs and projects have been implemented to reduce our information technology carbon footprint and minimize waste.
The Environmental Guidelines for Package Development direct our businesses to minimize the environmental impact of packaging by considering source reduction, recyclability, refillability, reusability and safe disposal. As a best practice, all packaging engineers consider the principles of sustainability during package design.
Our local facilities have years of experience demonstrating that pollution prevention makes good business sense. Pollution prevention reduces the environmental footprint of a facility and promotes economic growth through cost savings and productivity improvements.
Product Life Cycle Reviews
We integrate product life cycle concepts into the new product development process. Our approach to eco-efficiency includes: designing products that meet the highest standards of excellence with regard to quality, cost and EHS performance. By minimizing packaging, using recycled and recyclable materials and utilizing green chemistry principles to reduce the toxicity of our raw materials, we are decreasing the environmental impact of our products, including use and consumption by consumers. Utilizing green chemistry principles also enhances health and safety considerations associated with production of our products.
Bristol-Myers Squibb has a long tradition of open communication and cooperation on EHS issues. Internally, we foster communication and dialogue with employees through education initiatives and functional and cross-functional committees. Externally, we actively seek dialogue with investors, suppliers, customers, patients, environmental and public interest groups, local and national government leaders, the media and international organizations.
Bristol-Myers Squibb's comprehensive sustainability goals for 2010 ranged from environmental and safety performance to leadership development. Our Sustainability 2015 Goals address environmental and safety performance commitments (in addition to others) to our patients and customers, employees and global communities. As with our Sustainability 2010 Goals, we will track our performance against our Sustainability 2015 Goals worldwide and report both positive and negative progress to the public.
Waste Contractor Evaluation Program
Prior to the initial off-site shipment of waste, Bristol-Myers Squibb evaluates the proposed waste handling and disposal contractors. The purpose of the evaluation is to determine the capabilities of the contractors and review the contractors' compliance records to the extent possible. This includes an evaluation of whether the contractors have operated in accordance with our EHS Policy and applicable laws and regulations. By design, we limit the number of contractors used by our facilities so that we can maximize our knowledge of each contractor's capabilities. We review the status of our current waste contractors periodically.
Bristol-Myers Squibb develops and maintains waste minimization programs for its facilities. Waste minimization programs should cover all categories of waste generated at each location. Waste minimization goals are established and reports on progress are provided to management at least annually. Our corporate audit group reviews performance against these objectives. For more information about our waste minimization performance see the environmental performance section of this website.