Reviewing Workplace Sustainability Policy Implementation Questions and Answers

Activity 3  
  Please Tick True False  
  In order for plans to become effective, information must be properly communicated to employees and clear in their explanation.      
  When communicating your policy and convincing people to change, you should avoid considering how your target audience might react.      
  Once a sustainability policy has been formulated, you need to determine the best approach to implementation.      
  Sustainability programs are in a constant state of implementation.      
  The accuracy and consistency of you methods of recording are not important.      
  It is quite possible that through the course of implementing your sustainability plan and procedures that you will encounter ways that you can improve on the



Documenting outcomes and providing feedback to key personnel and stakeholders

The final stage when developing a sustainability is to monitor its effectiveness. This may be achieved through the collation of appropriate data, i.e. (results should be quantifiable) thus allowing for revision accordingly. “It is critical that a company monitors the changing developments that occur relating to their industry and the regulations. For example, it is of course better to know in advance that water reductions are required, then to find out by facing a significant bill. Keeping up to date on issues is essential to maintaining a usable policy”.

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There is as important interaction between policies and procedures. Feedback from procedures facilitates the policy developers in maintaining realistic expectations for sustainability within the company. Changes made within an organisation that inhibit the implementation of the policy, may require revisions in order to keep expectations realistic. When revisions, are made it is important that this information is passed on to staff and stakeholders regarding rationales and outcome expectations. For each revision it is important to consider the continued appropriateness of the scope and readdress the stages of policy development.

Any new undertaking or change within a business usually involves an element of risk. “Since sustainability policy is such a new area for companies to be focusing on, there may not be much data available for you to use in determining what results your sustainability policy should provide. Nevertheless, you still have your own data from your own center’s experience”.

continual improvementGradual, continual improvement, is more desirable than a sudden jump. These results are best illustrated in the form of a graph. This provides more meaningful information to stakeholders than stand- alone statistical data.

“In the process of graphing your data, there are two important points which must be shown, in addition to the data showing your improvement. The first of these is the benchmark, so that everyone can see how far you have come from the start. The second of these is the goal, so that  they can see how much farther you have to go. Knowing how far you’ve come will motivate people to keep trying. The goal will give them a challenge to try and meet.

You want to be sure to make your documents and reports as positive as possible, especially since this is a new area to your company. Applaud every success that your company or some part of your

company has. That will also help motivate people. If all you do is to talk about how much farther you have to go, without ever mentioning the victories that you’ve had, you won’t motivate them; you’ll surgically remove any motivation they have within them”.

ISO 14001 contains guidelines for reviewing an environmental management system. The material gathered during review of the ESP should be documented, and include information about:

  • outcomes and results
  • the extent to which objectives and targets have been met
  • the continuing suitability of your ESP in relation to changing conditions and information
  • Details about the concerns of relevant interested

An example of a review plan follows.

example of a review plan

Reviews of an environmental sustainability system require audits of the documentation and site visits to check the accuracy of information contained in documentation. During the review process

staff should be asked a range of questions so the reviewer can accurately assess how the system is operating. The questions should focus on answering the following questions.

  • Does the system meet the requirements of ISO 14001:2004 and other requirements set up by the organisation?
  • Are the operations occurring in an effective and efficient manner in accordance with the documentation that has been developed?
  • Are procedures in place and do staff understand the procedures?
  • Are the objectives and targets appropriate for the activities being audited? Are the objectives and targets being met?
  • Is corrective action taken when needed? Is the system reviewed following any incidents or emergencies?
  • What evidence is there that the system is continually improving?

Provide Feedback

Before giving feedback about the outcomes of your sustainability initiatives, you must identify a variety of audiences and tailor information to suit their needs.

Typically, an organisation will need to provide feedback to staff, and internal and external stakeholders.

TABLE 4.1: Example of internal reporting chart

(Adapted from ‘Developing an energy management system’, State Government of Victoria, pg.17)Developing an energy management system

Investigating successes or otherwise of policy

Once you’ve documented your progress, it’s time to start analyzing that progress. Have your sustainability efforts been successful to date? Are there areas where the company or some department within the company has outdone your expectations? Are there areas where your expectations haven’t been met? What’s going on?

Every success and failure needs to be investigated and analysed to determine why it was or wasn’t a success. There has to be at least one reason, if not several, in each and every case. Look for the following:

  • A particular person who has been the impetus behind the success
  • People who are ignoring the new policies and procedures
  • Equipment that is part of new processes, which either doesn’t work properly or is broken
  • Systems that are not running smoothly
  • Systems and procedures that are creating extra work for people
  • Changes in personnel, placing people in key positions who are not trained on your sustainability procedures
  • Problems with vendors
  • Outstanding vendors who have helped create a success.

Investigating successes

Don’t just accept what people say about these things, look for yourself. Often, the answer you receive from someone reflects their ideas, plans and desires, more than reflecting the true information that you need. Be your own person and seek your own answers to those questions.

Your goal is to see what lessons you can learn from what has happened so far, in order to seek out ways that you can apply those lessons to other parts of your center. If you have a success, and you

can find a way to copy whatever has created that success, you may turn another area, which hasn’t been doing all that good, into a success. At the same time, looking for what has prevented something from succeeding is the first step in being able to correct the problem and turn a failure into a success.

Never be closed minded to what works. Many people are so wedded to their own ideas or ideology that they are unable to accept something that is outside of those limits. You need to be focused on what works, not what you think will work. Results are the only measurement that matters.

As I mentioned earlier, there are times when the best thing to do is change plans. You may have had a great plan, but if it isn’t working, it’s time to look for another answer. Likewise, when something you didn’t expect would work, works, you need to be quick to embrace that thing, even if it goes against your ideas.10

The degree of success or otherwise of your ESP will be determined by the information you collect following audit of the ESP. This is why it is important to establishing measurable targets; without them, there would be no way to gauge your success.

Where variations between actual performance and the required standard are discovered, managers have three possible courses of action:

  • do nothing
  • identify and correct the cause of the variation
  • revise the

Where performance measures indicate that targets are being met or identify a variation from a target that is within acceptable limits, it is appropriate to do nothing.

Where a variation exists and the target is deemed to be acceptable, it will be necessary to identify the cause of the variation and correct the performance.

If a variation is identified and the target is thought to be unacceptable, it will be necessary to revise the target.

This process, illustrated in Figure 4.1, is a continuous flow with new measurements needed over time.

FIGURE 4.1: Comparing targets with actual performance

Comparing targets with actual performance

If you have studied BSBMGT608B Manage innovation and continuous improvement you may recall the importance of accepting failures and embedding successes into any sort of workplace innovation. The same applies to an ESP – rather than covering up failures, staff should be positively encouraged to report failures and what was learned from them.

Monitoring records to identify trends that may require remedial action and using to promote continuous improvement of performance

It is critical to continually monitor and revise the processes involved and compare results to expected outcomes. Reporting based on data collected should adhere to the construct of TRACE reporting. TRACE reporting incorporates the principles of:

  • Transparency: organised documentation that facilitates interpretation of data
  • Relevance: reporting serves the needs of the organisation and aids decision making
  • Accuracy
  • Consistency: consistent measures and procedures must be implemented in order to make comparisons over time
  • Entirety: boundaries must be clearly defined and all relevant sources must be included

Procedures need to be monitored and revised in relation to outcome expectations, in order to keep the sustainability policy focused and directed. Changes may need to be made if goals are not being met. Evaluating whether a procedure is effective will help further new initiatives, promote communications, and motivate staff towards continued excellence in sustainability commitment.

There is always room for improvement. A common goal within the business is to have the best possible sustainability policies and procedures in place. This will probably require repeated changes in procedures, seeking out “bugs” in your systems and developing strategies to combat them.

Ideally, areas in the business requiring improvement will be identifiable by looking at trends, instead of waiting until they fail. It may be that a change made previously showed significant initial improvement, but then the improvement slowed down as time went on. Upon investigation, you find that the initial improvement was due to the efforts of one individual, who is highly concerned with sustainability, but the rest of the centre hasn’t adopted the sustainability procedure, because it makes their jobs harder to accomplish.

“In this sort of case, you definitely need to revise the sustainability procedure you have put into place. Any procedure that sacrifices worker efficiency, in order to gain some other desired result is likely to fail. Most workers aren’t willing to put in the extra work necessary to make a more difficult procedure function well, especially when they know an easier way to get the job done

Modifying policy and or procedures as required to ensure improvements are made

Demanding that workers abide by the new policy in cases like this is no guarantee that they will obey the new policy. People can be very inventive, when seeking ways to get around a policy they don’t like. Instead, what you would need to do in a case like this is to find a way of making your sustainability procedure at least as easy as the other one, if not easier.

Sustainability policies and procedures are processes which are continually changing and evolving. As the environment is not “static”, policy and procedure change is necessary to address relevant issues accordingly.

Because the practice of sustainability is relatively recent, new techniques, technologies and theories are constantly being presented. This may in turn trigger new ideas and ways to improve your company’s sustainability policy and procedures. While there is no “one size fits all” approach which suits every organization, there are some which are commonly shared.

When employing new strategies and techniques to improve sustainability, it is important to update documentation accordingly. This ensure that your documentation is actually relevant to what you are doing. There is no point in making positive changes whilst the accompanying documentation remains out of date.

“The authority to ensure that the change is implemented is the policy and procedures. While you may be able to talk somebody into implementing a change, without the documentation being complete, both you and they are wrong. Should something go wrong with the new procedure, there will be no defined way for things to be handled. However, if you change the procedures to match the actual change, the people doing the work will have something to fall back upon Additionally, governmental regulations are constantly changing, becoming more stringent and requiring a constant re-evaluation of the way that we are doing things. What is considered acceptable levels of emissions today may be considered criminal tomorrow”.

A trend refers to the tendency for things or events to move in a particular direction.

In relation to sustainability, trend lines can be drawn to illustrate changes in variables such as resource use, expenditure, savings and energy consumption. Trends can be accurately plotted to show occurrences that may require remedial action, and can also be extended beyond the present  as a way of promoting continuous improvement in performance. Past trends are easy to plot, as this simply requires the utilization of existing data.

Modify policy and or procedures as required to ensure improvements are made

The next step in the cycle of continuous improvement of your ESP is to modify policy and/or procedures as required. This should be done in consultation with relevant stakeholders such as:

  • the board of management
  • heads of department
  • the CEO
  • team leaders
  • others specialists, such as occupational health and safety experts and risk management consultants.

The types of modifications will depend on the outcomes of your evaluation, but may address the following factors:

  • currency – what changes have taken place since the ESP was developed and implemented and are these changes likely to impact upon the ESP?
  • relevance, accuracy and completeness – does the plan reflect the priorities of the organisation? Does it help to distinguish the sustainability initiatives likely to have the greatest impact on the organisation’s environmental performance?
  • how much the policy is integrated into functional work area processes – is there a flow-down effect of the ESP to the rest of the organisation? Do operational areas know that it exists and refer to it in their goal and objectives planning? Do these areas review sustainability initiatives in their regular meetings or planning and review sessions? Is there a reporting mechanism for reporting sustainability issues?
  • changes that have occurred in organisational goals, policies and priorities – a review of the organisation’s strategic planning should be accompanied by a corresponding review of the ESP, in terms of its identification of key sustainability
  • areas that the ESP did not address, where sustainability has been an issue – most dynamic organisations will, from time to time, find that sustainability issues arise that that were not previously
  • areas or activities that have not met targets – a review of the areas of under performance may point to risks that the organisation should address; for example, constant under performance in relation to legislative requirements may point to a potential law suit and should be

Assuming an evaluation of your ESP identifies a number of issues that need to be addressed in order to improve current sustainability processes, you might consider the following options:

  • staff training to improve understanding of sustainability and how to implement the processes
  • making changes to processes, procedures


Case study: Review policy Mei

Congratulations everyone – you got here. Now let’s listen to our sustainability champions and how they went about letting their stakeholders know about the outcomes of their sustainability policies.



Some of the measures are reported on boards around the factory; with staff through the feedback session every quarter where we give them a full feedback on how the business is travelling both in regards to sales and profitability as well as how we’re travelling on improving sustainability. We do the same thing with the operator on the shop floor through toolbox meetings as well, they get the same information. So it’s a very open culture in that respect. We also put a lot of information on our websites.



We communicated the outcomes of our policy to key stakeholders in a variety of ways. We have an


annual report that discusses performance against our objectives, and those objectives then support the policy. Our significant sustainability achievements are also communicated on the internet externally to all our customers and suppliers, as well as internally on the intranet.

We’ve got HSE targets and objectives, they’re documented in what we call our HSE plan which are reviewed monthly and these are then communicated also to executive management also to our customers and our suppliers as well.



It’s all very well to have Key Performance Indicators and health and safety targets, but how do you prove the policy is actually achieving its objectives?



Basically by comparing back to the targets and metrics that we were focusing on – so if we were trying to get a water reduction to a certain point – then we looked back at whether we actually achieved that water reduction and if we did, explained how we did it. If we didn’t, explained why we missed it, and if we got better, explain how we actually got better, so it’s important to not only just state the numbers, but we also need to provide the context and narrative around them.



We are still not at our Mission Zero objective but we’ve done much better than where we were 10  or 15 years ago. The proof is there. It was not about going after a green agenda at the risk of becoming broke – there’s no benefit of being green and broke, it doesn’t benefit anyone. It was about remaining very profitable but by doing the right thing by the environment and this earth.



In your workplace you will have all sorts of data and software at your disposal. It can be confusing, and you have to use the right tools. Listen to the tools that our sustainability champions used to identify the results of their sustainability policies.



Basically just analysis of the data, and in that analysis, it’s predominantly just using spreadsheets.



The first tool we use is compliance. Our monitoring and compliance matrix. Every scorecard that we produce, and database has a KPI, minimal KPI we have to achieve. Also feedback from the guys if something is not working, or not working as well as we want, sit down and review what it is we’re trying to achieve. And I guess feedback from senior management in head office. A good test of that is ‘Can you make that available to us to the rest of the world?’

Continuous improvement is not a statement it’s a journey. One thing you can be sure of with us, we’re always in a state of continuous improvement or change whatever you want to call it. The process is simple, it has to be. It’s very visual.


We celebrate success, but we’re not naïve enough not to recognise failure either.



The key tools which we used to identify trends requiring remedial actions are audits and workplace

inspections, as well as our incident and hazard forms.



All staff report incidents and hazards to us centrally which are then recorded and we are able to analyse and track.


We also have a corrective and preventative action database that we use to measure and monitor those remedial actions to ensure that they’re closed down in time. They’re also reported to senior management so that it keeps that driven through our area to make sure they’re closed off within a timely period.



Lastly, how often do they review a sustainability policy?



In terms of the sustainability plan I’ve mentioned that is a three year document. So we look at that every three years.



The policy itself is not really reviewed because it’s been set basically in our DNA, if I can say. And this is Mission Zero by 2020 – that’s your whole measurement, it’s very simple, and very clear, and the objective doesn’t change and will not change.


What is reviewed regularly is how we’re progressing on that road and are we achieving the results and what we need to do between now and that 2020 date. That’s where on a regular basis we review that. So we’ve got several work groups for instance around the world – there is a work group looking at what you call our top cloth, our yarn usage, we’ve got a group looking at our backing, we’ve got a group looking at our process, a group working on our energy use. So those work groups are focused on some of the areas and saying what is the plan that needs to be put in place between now and 2020 to be there by 2020.


So that’s probably the way we review our process, by saying where are we at, how are we tracking, what do we need to do, what are the next step changes that we’ll need to make to get to our objective, because there will, you know, still be step-changes required between now and then.


The policy is reviewed annually within the organisation, at several levels within the organisation. We also have six monthly audits, where we have an external independent auditor come in and audit our environmental management system and he goes over the policy every six months, so that we ensure that we have a continual review of that policy.



And as we reach the end of the unit – these people all feel they are part of a changing work culture.



I think it is and I think that actually one of the areas that was probably faster to change than a lot of places – the reason I say that, we have a lot of operators that live on small properties out in the countryside, and so they know how acute the water shortage is far more than anyone else living in the city. We turn on a tap and we get water coming out. They don’t have any water in some of these

places that they’re living in. So some of the operators are very engaged in particular around water –


because they are actually seeing the impact of Melbourne’s drought far more than people in the city are.



We’re at a crossroads at this point in time, and we will continue to do this work. Where we need to probably go in the future will be, we need to look at the glass melting process. We cannot achieve the energy reduction targets that we need to achieve with the current method. There is some research and development going on at the moment, methods to melt glass, and I would think that is the future. Once we do that, they’re definitely add on, but if you’re talking 50% reduction in energy usage, this site here uses approximately $20 million of energy a year, you’re talking $10 million.



It’s not just about waiting for governments or political parties to make decisions, it’s about the industry taking the lead. Because we’ve demonstrated, and a lot of other organisations have demonstrated, that going onto the sustainability road, can bring a lot of benefits as well. It can bring a lot benefits around cost savings in regards to your position in the market, competitive advantage in the market, growth, etc. And so more and more people will go down that path. They will also be pushed by external stakeholders – consumers, and customers and shareholders will not be wanting to invest their money into products that is jeopardising the environment or buying shares for a company that down the track might be in trouble because it hasn’t been down that sustainability road.


So there will be a lot of pressure on some businesses which they will have to react. Some businesses will first do the minimum to try to comply with that, some will understand the message and see that ‘it’s a great opportunity for us’. I think more and more people, and that’s why we’re spending so much time in our business talking to people outside the business to spread the word, because that’s how we can have an impact.



I hope you enjoyed the unit. It really feels like something is happening out there – don’t you think? I’ll say goodbye for Carlo too – I think we’ve all had enough of him. Please think about what you’ve learnt and I hope you can use it to make changes in your workplace.

I’m going too – bye.