Upgrading (and Sustaining) The EMS:

Driving Continuous Improvement, Worker Safety, Sustainability, and Other

Key Attributes into the System -The Case of Western Digital Corp.

Presented by

Edward L. Quevedo

Pillsbury Madison & Sutro LLP

Environment & Land Use Group

Overview of Session

EHSMS Principles EHSMS Design Concepts Eco-Efficiency - the Master Metric The Hidden Attributes of the EHSMS The WDC EHSMS Vision and Mission The WDC Implementation Path EHSMS Design Consequences Lessons Learned and the Road Forward

EHSMS Principles

Decision Theory and Integration of the OSH Management System with the EMS

Choices among OSH Management System ModelsBSi 8800AIHA OSH Management System GuidelinesOSHA VPP Star

Design with the Future in Mind - Do we seek Sustainability or other Future Goals?

OSH Management System Models

OSHA VPP integrates well with NIOSH standardssimple framework

AIHA OSH Management Systems Guidelines incorporates JHA model robust framework - minimal design decisions

BSi 8800aligns with ISO 14001provides HSE guidancestate of the art model - maximum design flexibility

EHSMS Principles - 2

Practical Integration IssuesWorkforce sophisticationExisting management structureDelegation (not assignment) of responsibilityImplementation SchedulingRegistrar managementMaintenance of the EHSMS

EHSMS Design Concepts

An EHSMS will deliver precisely what it is designed to deliver - nothing more, nothing less

Design must be active and begin at project inception - a direct analogy to product design

The E(HS)MS as a ProductMust meet customer expectationMust be marketedMust be delivered on time and on budgetThe real value is in the use, not the deliveryThe product must be stewarded throughout its lifecycle

EHSMS Design Concepts - 2

Customer Design IssuesMarketing IssuesDelivery IssuesEco-Efficiency and the EMSE(HS)MS StewardshipThe Principle of Sustainability

Eco-Efficiency - The Master Metric

Existing Terms of Limited ValueComplianceEH&S “Performance”“Strategic” EH&S Management

The New Lodestar - Eco-Efficiency Each dollar spent and each person hour invested must be justified

as simultaneously aiding both the business and either Human Health and Safety or the Environment

Activities which do not pass the test should be subject to question, and to regulatory innovation discussions with Regulatory Partners

The Hidden Attributes of the EHSMSLeadership

Industry/Corporate/Site/Community

EducationWorkforce/Customers/Suppliers/Community

Trust Installing Wiring for Stakeholder Input

Organizational ReinventionFundamental Business NeedEHSMS is a reinvention engine (in the programme)

SustainabilityRetuning the EHSMS to Dial in the SMS

The WDC EHSMS Vision and Mission

WDC EH&S VisionWDC will be among the global industry leaders in the EH&S

performance of our products, processes, and business practices. We will partner with our suppliers, customers, and the communities in which we operate to maximize protection of personal health and the environment

WDC EH&S MissionMinimize EH&S risks and impacts while optimizing

operational efficiency through commitments to P2, legal compliance, and continuous improvement

The WDC EHSMS Vision and Mission - 2

Vision DocumentAligns with Policy StatementGives clear direction for management reviewArticulates clear basis for programme

Mission DocumentAligns with Objectives Provides grounding for executive and employee

performance reviewsIntegrates into MDs’ business plans

The WDC Implementation Path

Initial Review - follows EMAS model for maximum impact in design and manufacturing phases

Modeling of QMS - to optimize integration and improve QMS through the implementation process

Learning Organization Model - to utilize each education session as an opportunity for continuous improvement

WDC ImplementationSanta Clara, California

Challengessize of sitemanufacturing processMD management style

- “hands-off”history of program

implementationposition in

manufacturing cycle (media facility)

Opportunities/Solutionsexpand EHS criteria redesign opportunities inclusion of more

middle managersmonthly milestones -

gain interest/buy-in include core business

metric in EHSMS objective set

WDC ImplementationKuala Lumpur, Malaysia

Challengesnumber/literacy of

workers

complexity/variety of processes

number/variety of functions

personality of EMRgrowth of site

Opportunities/SolutionsMD loyalty and

leadership/expanded training

increase in metrics, not criteria

allow aspects and ranking to involve more input, time

EHSMS becomes planning tool

EHSMS Design Consequences

Intervention with Financial PartnersIntervention with RegulatorsCommitment to Continuous Off-Line, Non-

Production Education of Employees + Key Alliance Partners (the Learning Organization expands)

EHSMS Design Consequences - 2

Share (Internally and Externally) Innovations and Successes of Divisions or Sites to Inspire Others Taking and Sharing Credit

Hard wiring EH&S Quality Performance to Performance Reviews and Compensation Top-down model

Tap Creativity of WorkForce, Solicit Participation to Inspire Creativity, and Reward Creativity When Displayed Cultural and Financial Challenge - requires “plowing back”

Stabilizing the EHSMS Continuously Learn and Synthesize New Learning

Changing the Audit Protocol and Approach• Stage I - Protocol Has Mentoring and Training Effect - “Is there a

Policy Statement?”

• Stage II - Protocol is a Re-Design Engine - “Is The Policy Adequate? Can/Should we improve it based on business conditions/environmental conditions/market conditions/community issues or concerns?”

Stage II EHSMS Programs Regulatory Reinvention Life Cycle Inventory Supplier Management Community Outreach/Environmental Reporting Migrating Toward Sustainability

Lessons Learned and the Road Forward

Efficiency in Design - align objectives with metrics to show quick returns

Accuracy in Design - requires mapping of the manufacturing process

Innovation in Design - the value of the Learning Organization Model

Eco-efficiency - the opportunities for regulatory reform Challenges - regulatory reform and supplier

management

Discussion: Future Challenges

Entry of CompetitionRevisions to ISO 14001/14004New TechnologiesNew GeographiesOthers??

Edward L. QuevedoPillsbury Madison & Sutro LLPEnvironment & Land Use Group

San Francisco: 415.983.1125

Silicon Valley: 650.233.4766

___________________

quevedo_el@pillsburylaw.com

http://pillsburylaw.com

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