FIGURE 3 SEEP data from a Ciba company (example). t = ton; m3 = cubic meter; TJ = tera joules.

Analysis of the SEEP data in this way provides a picture of environmental achievements from a broad operational perspective and aids in setting further goals and performance standards. However, although a graphic such as Figure 3 is effective in summarizing accomplishments across the company, it is really analysis of trends in specific site data from year to year (either by using an analysis similar to that illustrated in Figure 3 or another method) that allows targeting of specific areas for improvement.

As mentioned previously, data associated with environmental performance measurement systems can be quite voluminous, especially for large, multinational corporations. Hence, in 1993, after 3 years of experience with implementing SEEP, Ciba automated and computerized the process. Also, Ciba recently retained an independent firm to access the SEEP program. The objectives of this independent assessment were to critically review and assess the process for collecting and analyzing the SEEP data from group companies and provide a validation assessment of the 1993 SEEP data for publication in the annual corporate environmental report.

Four years of experience with SEEP and the recent independent assessment reveal an important additional complexity for interpreting and using SEEP information as a management tool: Different measurements are required to assess environmental performance at different levels of facility operation. For example, measurement of wastewater releases from a production area to either on-site or



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