Summary

WHAT ARE ENVIRONMENTAL MANAGEMENT SYSTEMS?

Environmental management systems (EMSs) are tools that corporations and some government agencies use to manage environmental issues. These systems may vary from facility (or agency) to facility but the basic premise is to implement the broader concept of sound and proactive environmental management. In recent years, EMS has evolved further to respond to increasing stakeholder pressure to improve social responsibility. As more companies, federal agencies, and organizations choose to implement EMSs, such as ISO 14001, it is important to consider the current state of the research concerning the relative successes and obstacles associated with existing systems in practice and what impact it will have, if any, on environmental health.

Despite wide implementation, EMSs are frameworks, or a tool, noted Edward Pinero of the Office of the Federal Environmental Executive. They vary in their content, coverage, and spectrum. EMSs have both operational and general benefits, remarked Pinero. EMSs can be used to improve the organization at large by facilitating the achievement of mission goals by systematically and operationally capturing environmental issues. In addition to increasing the awareness of impacts, consistency in operations, and promoting a more effective corrective action when problems occur, successful EMSs ultimately improve the condition of the surrounding environment.

Although the benefits of EMSs suggest improved performance, researchers are beginning to understand where, when, and how improvements are achieved. Deanna Matthews of Carnegie Mellon University has conducted research concerning the link between EMSs and improvement in environmental performance. From her research she learned that successful management systems support decision makers, evaluate and select projects based upon an organization’s goals, and

The roundtable’s role was limited to planning the workshop, and the workshop summary has been prepared by the workshop rapporteurs as a factual summary of what occurred at the workshop.



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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary Summary WHAT ARE ENVIRONMENTAL MANAGEMENT SYSTEMS? Environmental management systems (EMSs) are tools that corporations and some government agencies use to manage environmental issues. These systems may vary from facility (or agency) to facility but the basic premise is to implement the broader concept of sound and proactive environmental management. In recent years, EMS has evolved further to respond to increasing stakeholder pressure to improve social responsibility. As more companies, federal agencies, and organizations choose to implement EMSs, such as ISO 14001, it is important to consider the current state of the research concerning the relative successes and obstacles associated with existing systems in practice and what impact it will have, if any, on environmental health. Despite wide implementation, EMSs are frameworks, or a tool, noted Edward Pinero of the Office of the Federal Environmental Executive. They vary in their content, coverage, and spectrum. EMSs have both operational and general benefits, remarked Pinero. EMSs can be used to improve the organization at large by facilitating the achievement of mission goals by systematically and operationally capturing environmental issues. In addition to increasing the awareness of impacts, consistency in operations, and promoting a more effective corrective action when problems occur, successful EMSs ultimately improve the condition of the surrounding environment. Although the benefits of EMSs suggest improved performance, researchers are beginning to understand where, when, and how improvements are achieved. Deanna Matthews of Carnegie Mellon University has conducted research concerning the link between EMSs and improvement in environmental performance. From her research she learned that successful management systems support decision makers, evaluate and select projects based upon an organization’s goals, and The roundtable’s role was limited to planning the workshop, and the workshop summary has been prepared by the workshop rapporteurs as a factual summary of what occurred at the workshop.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary reduce liability or risk to the organization. They also support the general goals of a successful management system through proactive and cost-effective methods to improve operations to achieve better overall performance. There remains a need to bridge the information gap between the leadership and management system components of the organization and for EMSs to address potential problems, especially non-regulated public health needs. In addition, a better communication between firms and stakeholders is needed, concluded Matthews. Some meeting participants suggested that EMSs cannot be generalized and that we need to move forward toward a more sustainable approach to governing. We need to recognize that organizations need a wide range of incentives and disincentives, and they need to be given every possible tool to assist them toward their goals. A combination of approaches coupled with command and control regulation, insurance and supply chain incentives, and community pressure will lead to sustainable improvement after a few years, noted general discussion participants. The Environmental Impact of Environmental Management Systems Environmental performance is defined by the reduction of pollution or other kinds of resource uses, whether it is water or energy use, said Cary Coglianese of the Kennedy School of Government, Harvard University. Although EMSs are initially implemented to maintain compliance with regulations, they often have implications for lowering environmental costs, training employees, and developing indicators for environmental impact. An effective EMS enables an organization’s officials and stakeholders to examine its values, priorities, policies, strategies, objectives, methods for allocating resources for delivering performance, and learning. Some research suggests that EMSs can manage risks, gain competitive advantages, and achieve environmental improvements at lower costs. During the workshop the speakers, Roundtable members, and participants considered how companies could use EMSs and other tools and policies to achieve greater impact beyond regulatory compliance. Coglianese suggests that required EMSs can and do make environmental improvements, but one must use caution in distinguishing how much comes from the system and how much comes from the commitment. USING ENVIRONMENTAL MANAGEMENT SYSTEMS TO IMPROVE PERFORMANCE IN THE CHEMICAL INDUSTRY Being a $450 billion-a-year enterprise, the chemical industry in the United States is a key element of the country’s economy and nation’s largest exporter, accounting for 10 cents out of every dollar in the U.S. exports, said Gregory Bond of Dow Chemical Company. The chemical industry is critical to a wide variety of markets essential to human needs, such as food, transportation, electronics, health and medicine, personal and home care, and building and construction. In

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary addition, chemistry companies invest more in research and development than any other business sector. The industry has had a long history of conducting testing, exposure, and risk assessment in practicing product stewardship. It has recognized for a long time that some of its products are inherently hazardous and is therefore continuing its commitment to evaluate risk responsibly. The industry is participating in developing sound public policy and trying to improve its communications; however, there is room for improvement, said Bond. Sixteen years ago, the industry recognized the importance of improving environmental health and safety performance and their dialogue with the public and launched Responsible Care, which evolved into an environmental health and safety management systems approach. Today’s chemical industry is very sensitive and responsive to the growing number of public concerns regarding the use of chemical products, said Terry Yosie of the American Chemistry Council. The chemical industry attempts to design programs that focus on product safety and health. One of the programs adopted in the United States in 1988 is Responsible Care. Responsible Care focuses on outreach, dialogue, and interaction of stakeholders and connects the initiative with the actual business operations within chemical companies as well as their business partners. Other companies, such as Xerox, are trying to minimize their contribution to pollution by discovering ways to use their products responsibly. Xerox does not manufacture paper; it buys finished and already packaged paper and distributes it, said Jack Azar of Xerox. Therefore, the company has certain environmental requirements to the company’s various suppliers and encourages them to be more environmentally responsible. Xerox’s suppliers have to meet the following requirements: (1) compliance, wherever the supplier is operating; (2) effective paper mill EMSs; (3) manufacturers that control their own forests must have those forests third-party certified; (4) manufacturers that buy fiber and convert it through their mills into finished paper have to receive a third-party chain of custody certification. Today, 82 percent of the 60 suppliers worldwide that Xerox uses for paper are in compliance with the requirements. Green Chemistry According to the Wall Street Journal, the pharmaceutical industry spends $90 billion a year to manufacture drugs (Abboud and Hensley, 2003). Many companies in the pharmaceutical industry are using green chemistry principles at commercial scale, but possibly hundreds of millions of kilos of waste could still be prevented by broadly adopting green chemistry, said Berkeley Cue of the Green Chemistry Institute. The pharmaceutical industry is devoted to discovering and developing new medicines that will enable patients to live longer, healthier, and more productive lives. Sustainability and environmental health are important to the industry for its environmental, economic, and social performance. The

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary pharmaceutical industry is exploring the possibilities to make existing commercial manufacturing processes more environmentally friendly. According to Cue, the real battle yet to be fought is going to be in the laboratories, especially with the discovery of chemicals and start to set the strategy for how chemicals are going to be synthesized throughout the life-cycle. Industry Volunteerism Industry plays an essential role in the generation of hazard data, but there are limitations to that role, and there are very important roles that government needs to play, said John Balbus of Environmental Defense. Industry volunteerism does not include the need for substantial government resources. The voluntary programs are very beneficial, but they still require substantial government resources for monitoring, tracking, third-party validation, and dissemination. There is an inevitable conflict of interest in the voluntary programs, and that may be putting some limitations on the products of these programs. Thus, voluntary programs seem to work best where there is a good regulatory backstop, noted Balbus. Industry volunteers in a number of programs that are not required by the government regulations. Such programs include the High Production Volume (HPV) Challenge, the Organization for Economic Cooperation and Development Screening Information Data Set (OECD-SIDS) program, and the Voluntary Children’s Chemical Evaluation Program (VCCEP). GLOBAL IMPLICATION OF ENVIRONMENTAL STANDARDS Central to any country’s environmental program is their management of the tens of thousands of chemicals used daily in commerce. Although a sound chemical management program is the keystone for ensuring both public health and healthy environments, determining which chemicals to monitor and how to implement the program provides a challenge for all countries, whether they are developing or developed. During the workshop, Roundtable members, speakers, and participants discussed the management approaches in Europe, the United States, and Canada and the implications for improving management of chemicals around the world. The challenges of risk and risk assessment in protecting public health through regulation of chemicals requires looking at the changes in Europe, according to Bernard Goldstein, Graduate School of Public Health, University of Pittsburgh. Central to the current debate about environmental control in the European Union is the precautionary principle. The Rio Declaration defined the precautionary principle as: “Nations shall use the precautionary approach to protect the environment where there are threats of serious or irreversible damage. Scientific uncertainty shall not be used to postpone cost-effective measures to prevent environmental degradation” (United Nations Conference on Environment and Development, 1992). According to Goldstein, the precautionary principle is one

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary of those positive statements with which, in principle, everyone can agree. It is similar to the idea of sustainable development—something that is loosely defined. However, he noted that the use of the precautionary principle in a legal framework suggests the need for further scrutiny. Invoking the precautionary principle requires some degree of scientific uncertainty about the worst case. If there was scientific certainty, there would be no need to invoke the precautionary principle. Further, the precautionary action needs to have significant economic or social costs. If the costs were trivial, the action would be taken without the need to invoke the precautionary principle. In essence, the precautionary principle is used for situations in which resources are to be invested, despite there being no surety that adverse consequences will occur. Thus, the more precautionary a country is, the more often that it is going to spend money, resources, and social capital for the wrong reason. Goldstein argued that one needs to build in an evaluation to determine if the precautionary approach is warranted. The more precautionary a country is, the more often that it is going to spend money, resources, and social capital for the wrong reason. —Bernard Goldstein Global Corporate Policies on Health, Safety, and the Environment Voluntary corporate policies can provide improved protection of human health and the environment, particularly in poor countries, noted Barry Castleman, Environmental Consultant. The vacuum of regulation and liability in many countries has allowed global corporations to operate without applying safeguards required of them in Europe and the United States. The tragedy in Bhopal, India, in 1984 brought the issue of corporate “double standards” to the world’s attention. Numerous safeguards in effect in the United States, such as plant design, safety systems, and maintenance, had been neglected at the company’s plant in India, noted Castleman. After the tragedy in Bhopal, multinational corporations began to issue global corporate policy statements based on the premise that there was no justification for operating a chemical process under less strict conditions of pollution control and worker protection in one country than another. In order to be successful, these company standards have to be applied to all aspects of production and marketing, stated Castleman. Some corporations assert responsibility for not only their subsidiaries but also their suppliers by auditing the occupational and environmental conditions of these suppliers and requiring conformity with corporate standards. On the other hand, companies that transfer environmentally dangerous production to other ones, where they appear as the customer but not the manufacturer, can make no claim to corporate social responsibility.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary Further, the same care needs to be applied in marketing of the products. “Double standards” issues arise in labeling, worker training, and product stewardship. For example, pesticides withdrawn for uses in the United States should be withdrawn for those uses worldwide, asserted Castleman. Another example is hazardous waste disposal in countries that do not have the proper facilities set up by the government or under some governmental regulation. In such countries, a responsible company should practice same policies of hazardous waste disposal as required in the United States. In addition, there needs to be public disclosure of toxic releases worldwide, stressed Castleman. Corporations in the United States often have policies not to sell chemicals to companies that do not use them in a reasonably sound manner. This practice needs to be corporate policy in other areas of the world, regardless of liability considerations, asserted Castleman. The REACH Initiative The European Union has the same issues as the United States but in a much more crowded situation, noted Robert Donkers of the delegation of the European Commission to the United States. The European Union has more than 450 million people in an area half the size of the United States. REACH is a response to the opinion in the EU that the burden of proof of what chemicals are not safe is no longer on the authorities. Rather, it is on industry to prove that its chemicals can be used safely. Currently, the burden lies with the government, which needs to spend enormous resources to ensure that the chemicals can be used safely, noted Donkers. The European Union is looking at REACH as an opportunity to ensure that industry is doing what they promised for years—responsible care and product stewardship. The REACH initiative, according to Donkers, will be based on information and science provided by industry and checked by authorities to determine if the EU needs to take management action. The precautionary principle will be invoked when industry will not play its role and does not deliver the information necessary; and, on the basis of information available, it would be irresponsible to wait to take action. In the European Union, measures enacted on the basis of the precautionary principle are not permanent, and are regularly reviewed on a case-to-case basis as more scientific information comes available. Working with REACH: Practical Observations James Bus of Dow Chemical Company suggested that industry should not be viewed as pushing back on the REACH initiative in the context that it should not move forward. Rather, he noted that the initiative is a complex new piece of regulation that affects the marketing of chemicals in the European environment. It is reasonable to have a robust dialogue between the government agencies, affected

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary parties, industry groups, and other stakeholders to ensure that ultimately there is a legislative outcome that achieves the purpose that was originally intended. Bus suggested that the need for reform is real—both in Europe and the United States—where there is a distinction between new and existing chemicals. Dow does have an extensive database that has information on where their chemicals are being utilized. However, it is not a perfect system. There is an opportunity for improvement. Any system that gives a greater degree of confidence of the full (breadth) of uses of the chemical helps to elucidate the potential risks, acknowledged Bus. In conclusion, Bus suggested that as the REACH program moves forward, there is a need to have a productive dialogue between industry and the European Union authorities. This continued dialogue can help to achieve REACH’s objectives by putting in place a chemical management program that achieves improvements and refinements in understanding human health and risk. Canadian Environmental Protection Act The Canadian Environmental Protection Act (CEPA) is the primary federal legislation in Canada that is used to protect human health from environmental risks. As broadly defined, substances of concern are both organic and inorganic matter and include almost anything in the environment that could be a potential hazard to human health, noted Daniel Krewski, Institute of Population Health, University of Ottawa. CEPA was introduced in 1988 and is required by law to be reviewed periodically. CEPA is focused on national issues, but done in cooperation with the provinces. Primarily, the provinces are responsible for health protection; but trends, boundary issues, issues of national concern such as air quality are implicit in the scope of CEPA. The provinces and the federal government work jointly to implement the intent of CEPA through a series of federal provincial committees (e.g., the committee on environmental health, the committee on drinking water). The act contains a number of key features, including jurisdiction and management. There is a shared jurisdiction of implementing CEPA between the federal Department of Health and the federal Department of the Environment. Primarily, Health Canada oversees the health assessments, and Environmental Canada oversees the environmental assessments. However, decisions on control measures are determined jointly by the two ministers of those departments following consultation with a broad range of stakeholders, according to Krewski. CEPA differs from the U.S. Toxic Substance Control Act (TSCA). Krewski suggested that one of the main differences is that under CEPA, there is a broader scope for looking at non-regulatory options, such as the use of multi-stakeholder issue tables, and allowing industry and the public to participate in the development of proposed risk management activities.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary U.S. Approach to Regulation: The Toxic Substance Control Act and Public Health It is important to note that when discussing chemical management that some of the management is outside of chemical statutes and that their management occurs in media-specific statutes, noted Lynn Goldman, Bloomberg School of Public Health, Johns Hopkins University. One example would be certain air pollutants covered by the Clean Air Act. These chemicals are interpreted through specific approaches that are often based on an engineering approach and are not usually a risk-based approach. Media-specific approaches are not very conducive to looking at a chemical from cradle to grave, which considers the entire life cycle of the chemical or a process. Media approaches can push a chemical from one medium to another, but never quite address the life cycle and what the alternatives might be, noted Goldman. The life cycle of a chemical starts with research and development, through production, and then use by workers. The use of the chemical can often be just as important as the production. However, often a regulator of a chemical does not have information about use. It is difficult to do a risk assessment without knowing about use and exposure, she noted. The standard for TSCA for all chemicals is the unreasonable risk standard. This standard is more than a common denominator—it doesn’t differentiate between the types of exposure, the quantities of exposures, or the scenarios for exposures. In addition to the factor of risk, it also includes whether the risk is reasonable in proportion to the costs that are required to control it. A significant burden on the government to prove that a standard has been met has rendered much of TSCA ineffective, noted Goldman. One of the challenges under TSCA is new chemical approvals. New chemicals and existing chemicals are treated differently by the regulators, thus creating a bias in the law against bringing new chemicals into the market. It is easier to continue to use existing chemicals because there is little likelihood that they will be evaluated. Under the Pesticides Act, a company cannot bring a new chemical on the market without testing and approval; however the EPA can establish categories of exemptions. TSCA does not require a testing prior to submitting a new chemical to the EPA. A second challenge under TSCA is existing chemicals. At the time that TSCA went into effect, approximately 70,000 chemicals were grandfathered into use and placed on the inventory. This is not a true list as some of the chemicals are mixtures and some chemicals have overlapping structures. However, the point is that there is a volume of chemicals in commerce, and primarily the focus has been on high-production chemicals. This again is a limitation of TSCA as it has not been very beneficial in producing data. Every year, there are a few chemicals that undergo testing through the use of test rules; however, to get a test rule written, the government needs to make a proof of unreasonable risk in order to have the chemical tested. Without any data on hazard and exposure, it is difficult to have a test rule written, observed Goldman.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary There is very little rule making and risk management out of the EPA as a result of TSCA. This means that all the risk management for chemicals occurs under statues like the Clean Air Act and does not occur under the laws covering chemicals. The result is that the government focuses on end-of-the-pipe solutions rather than pollution prevention-related solutions. It further creates problem with shifting pollutants between media as discussed earlier. TSCA does not reward efforts to develop safer processes of resource reduction, and it does not replace media by media-specific regulations. International Cooperation on Regulatory Issues In 1990 as preparations were underway for the UN Conference on Environment and Development (UNCED), there was a heightened interest and activity in addressing toxic chemical issues. There have been some international mechanisms established to coordinate the efforts of international government organizations and other international stakeholders in addressing the UNCED’s goals. Currently, there are at least 52 global and regional agreements that address the use of chemicals. There were 7 agreements in the 1970s, 13 in the 1980s, and since 1990, there have been 30. These agreements cover air pollution, water pollution, biodiversity, specific toxic chemicals, chemical weapons, industrial accidents, storage and transportation, trade in chemicals, and trans-boundary waste. The problem facing the international arena is how to work with the plethora of agreements. At the World Summit on Sustainable Development in Johannesburg in 2002, the world leaders were “aiming to achieve, by 2020, that chemicals are used and produced in ways that lead to the minimization of significant adverse effects on human health and the environment” (Johannesburg, 2002). It was noted in the specific recommendations that both technical and financial assistance will be needed for developing countries and economies in transition to build their capacity. INDUSTRY’S CONTRIBUTION TO IMPROVING THE GLOBAL COMMUNITY’S HEALTH We are living in a fragile, complex, and dangerous world, said Djordjija Petkoski of the World Bank. Imbalances in the world, such as the wealth gap, generational gap, and poverty, have direct impact on environment and health. Poverty has a substantial impact on the environment because the poor have less access to information and services; less formal or non-relevant education is associated with risk behaviors, especially by youth; and economic need forces poor women and migrants into risky work environment that poses high risk in communicable diseases. Furthermore, poor neighborhoods tend to have fewer doctors and pharmacies, inadequate transportation and recreation facilities, and lower availability of healthy food and clean water. Without these services it is difficult, if not impossible, to provide access to basic public health systems.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary The lack of institutional capacity and sound governance contributes to many of our global community health concerns. If a country’s energy capacity is developed, we have the potential to enhance a community’s access to economic, social, and health resources, said Brian Flannery of ExxonMobil. Capacity building is therefore a necessary step toward improving community health. Energy companies such as ExxonMobil Corporation have the potential to develop capacity and, consequently, alleviate poverty. Issues of global community health can be examined from a number of perspectives, including EMSs, policy implementation, and CSR. The ExxonMobil Chad-Cameroon oil pipeline project illustrates the principles of community health management. This project involved the construction of an oil pipeline from ExxonMobil’s oil production facility in Chad through neighboring Cameroon to the African Coast. This large-scale project had numerous environmental, health, and economic impacts. The strategies for managing these impacts were sometimes cited as examples of successful implementation; however, there were weaknesses in these strategies and methods for filling in the health gaps left by ExxonMobil’s pipeline project, noted Flannery. Before construction could begin, ExxonMobil had to develop a strategy to address the social, economic, community, and structural challenges that such a large-scale project would pose, said Andre Madec of ExxonMobil. In both Chad and Cameroon, ExxonMobil created health management plans to protect the health of pipeline workers and communities neighboring the pipeline. One of the major public health initiatives established by ExxonMobil during oil pipeline construction was the Community Health Outreach Program (CHOP), noted Burton Singer of Princeton University. The general objective of CHOP was to target selected health issues in communities potentially affected by the oil pipeline project while specifically focusing on locations in the vicinity of permanently staffed project field facilities. Strategies for the implementation of CHOP included (1) focusing on specific diseases and public health conditions most likely to affect the oil pipeline workforce or the larger community affected by the project; (2) initiating the program during construction and operation phases; (3) adapting support projects to varying socio-cultural settings; and (4) targeting education and other preventive and curative project-related health issues. CHOP’s successful programs have application potential throughout Chad and Cameroon. By collecting health and environmental data on ExxonMobil’s programs, regional health plans can be developed to incorporate CHOP’s successful techniques. CORPORATE SOCIAL RESPONSIBILITY CSR has gained more interest in the past decade, however it is not a new idea; it dates back to the 1930s, said Eric Orts of the University of Pennsylvania. Just before World War II, a German industrialist Walter Rathenau claimed that business corporations have become very large and that they had grown to be a

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary significant part of the society. According to Rathenau, even though fundamentally a corporation’s intent is the pursuit of private interests and profits for owners of the company, they increasingly are bearing the marks of an undertaking and, to an increasing degree, have been serving the public interest (Kessler, 1930). Further, philosophers John Dewey and James H. Tufts in their book Ethics, published in 1908, raised the concept that it is not sufficient to view companies as purely economic machines, and that companies should be involved in public duty as well (Dewey and Tufts, 1908). CSR is not a static concept—it is a moving, evolving target, said Norine Kennedy of the U.S. Council on International Business. According to Kennedy, there is no solid definition of CSR; however, it is not a replacement for the governmental role and responsibility in meeting challenges of sustainable development. The scope of corporate responsibility varies country by country, region by region, interest group by interest group. At a minimum, it includes environmental issues, but it also takes on social, ethical, governance, health, and other issues. Potentially, it is a very broad concept to cover, and it is a challenge for the business community. The phenomenon of CSR emerged because of globalization, stated Kernaghan Webb of Carleton University in Ottawa. Globalization increased movement of people, goods, ideas, and corporate activity across borders. The underlying premise of CSR is that organizations should behave with equal respect to people and the world, wherever they are. Advances in telecommunications (e.g. the introduction of the Internet), NGO activity, and media scrutiny mean that an organization’s activities can be critically tracked and followed more easily than ever before, regardless of their location. CSR is largely a phenomenon that is resulting from lack of state capacity, stated Webb. The result of the phenomenon is a growing expectation that firms should be economically, environmentally, and socially responsible. At the same time, these expectations apply to small, medium, and large firms, and all sectors: pharmaceutical, mining, refineries, chemicals, and so on, wherever they operate. Many initiatives are attempting to develop flexible, practical, standardized approaches for a global economy. Intergovernmental-level initiatives include such initiatives as Global Compact, the International Labour Organization declarations, OECD guidelines, the World Bank, and others. Individual governments such as the United Kingdom are taking lead roles as well. Other initiatives include investment, standards, industry, and NGO-driven and faith-based initiatives. Although all the initiatives indicate considerable engagement, there is a big challenge with content, comprehensiveness, interoperability, and take-up, said Webb.

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