We currently maintain nearly 400 facilities, including more than 170 manufacturing plants around the world. No two facilities are alike. There is a great range among them in terms of size, function, processes and local environment.
All GM-owned and operated facilities, however, operate under a common set of Environmental Principles, which provide an effective foundation for environmental stewardship and support our efforts to build the most valued automotive company.
As a responsible corporate citizen, GM is dedicated to protecting human health, natural resources and the global environment. This dedication reaches further than compliance with the law to encompass the integration of sound environmental practices into our business decisions. The following Environmental Principles provide guidance to GM personnel in the conduct of their daily business practices.
GM has a robust process to enhance the integration of environmental sustainability practices into daily business decisions and to (1) comply with applicable environmental laws and regulations; (2) monitor GM’s performance according to GM’s own Environmental Performance Criteria (EPC), which are universal performance requirements designed to protect human health and the environment in accordance with the GM Environmental Principles and set baseline standards; and (3) conform to other key performance indicators, such as landfill-free sites.
Each GM manufacturing site has one or more environmental engineers, who are supported by a GM regional environmental team. Our Global Manufacturing organization oversees and manages these teams. We also have an annual business planning process, known as Business Plan Deployment (BPD), to strengthen the management of environmental performance (e.g., linking more Global Manufacturing employees to GM’s performance against our 2020 manufacturing commitments). Furthermore, throughout our manufacturing organization, annual compensation is based on performance to the BPD, which includes environmental metrics.
We believe our past achievements in the area of environmental stewardship are the result of a combination of global principles, our environmental policy, the EPC and local policies. With our Environmental Principles as a foundation, this combination provides a framework for our manufacturing and nonmanufacturing facilities and major technology centers around the world to implement global policy, consistent and complementary local policies and the EPC. This approach helps us to strive for operational compliance across all sites at all times and to embed a philosophy of continuous improvement into each facility’s environmental management system. These plant-specific actions play a significant role in our overall environmental compliance, ensuring that local plant policies:
Statutory, regulatory and permit programs administered by various governmental agencies impose numerous environmental requirements on our facilities and products and compliance with these requirements is an organizational imperative. Compliance issues occasionally arise and each allegation of noncompliance is treated seriously. In 2015, GM received 34 Notices of Violation (NOVs), 20 in the U.S. and 14 outside the U.S. In 2015, actions were taken to resolve these NOVs and GM did not pay significant fines.
All the manufacturing facilities that GM owns and operates, and a number of our nonmanufacturing sites around the world, have implemented an Environmental Management System (EMS). This system combines elements of the environmental management standard International Organization for Standardization (ISO) 14001 and elements that are specific to our operations. The GM EMS is designed to drive a continuous performance improvement cycle in line with legal requirements, site-specific objectives and targets, and corporate and regional policies and strategies.
GM has developed a robust internal process to self-declare conformance to ISO 14001. Our U.S. and Mexican operations use this process to self-declare conformance to the ISO EMS standard. GM operations in other regions currently utilize third-party accredited registrars to certify conformance to ISO. New manufacturing operations must develop and implement EMS within 24 months of the start of production or the date of acquisition. Our operations in the U.S., Canada and Mexico have integrated their EMS within the GM Global Manufacturing System and Business Plan Deployment process, resulting in an EMS with attributes beyond those specified in ISO 14001.
By maintaining a common EMS, we can measure our environmental performance and share knowledge, processes and technologies within GM to plan and measure improvements across all our manufacturing facilities. Our environmental management practices have helped us improve our environmental performance.
Implementation of our Environmental Principles is facilitated by Environmental Performance Criteria (EPC) that apply to our global manufacturing facilities and major technology centers. In 2015, we made the decision to expand EPC application to our nonmanufacturing facilities and are working toward implementation of this during the next 12 to 18 months. The EPC are internal performance requirements for the management of environmental issues at our facilities. In many cases, they also supplement applicable legal requirements by setting minimum standards for environmental management and performance practices that may be more stringent than those required by law. As a result, we work to ensure that a base level of environmental performance is achieved, regardless of where a facility is located or whether a particular jurisdiction has an environmental regulatory program in place. For example, the EPC establish a global baseline standard for all new assembly operations with regard to paint shop emissions and associated minimum technology requirements, regardless of whether or not the country in which the paint shop is operated has adopted specific air emissions requirements. Where laws are more stringent than our EPCs, the law controls.
Our people are key stakeholders in our environmental stewardship and are critical to our environmental performance. We strive to have the best-trained environmental professionals in the world. Although most environmental training is specific to the facility, country or region, we continually provide strategic training and guidance to our environmental professionals to help them keep pace with evolving environmental issues and best practices that could have application worldwide. Our training addresses a variety of issues including, but not limited to: implementation of corrective and preventive actions, effective use of safety data sheets, management of greenhouse gases and regulatory requirements for air, waste and water.
In the U.S., we have set a goal for all our facilities’ environmental professionals to become Certified Hazardous Materials Managers (CHMM®). The certification requires a relevant degree and three years of appropriate experience or 11 years of experience without a degree, and the successful completion of an Institute of Hazardous Materials Management® exam. In order to maintain certification, at least 20 hours of technical environmental training is required annually. In Canada, new environmental professionals receive at least 40 hours of training initially, followed by regular refresher training. In addition, some Canadian environmental professionals receive specialized training as certified toxic substance reduction planners. Outside North America, we have developed a Global Environmental Certification and Training Program focused on GM Environmental Principles, our internal environmental performance criteria and industry best practices.
*Automobile Manufacturing Environmental Regulatory Profile Prepared by Horizon Environmental Corporation, December 2014.
See more at: www.gm.com/vision/environment1/our_commitment.html