Upgrading and Sustaining The EMS Driving Continuous Improvement

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

EHSMS Principles Ø Decision Theory and Integration of the OSH Management System with the EMS Ø Choices among OSH Management System Models äBSi 8800 äAIHA OSH Management System Guidelines äOSHA VPP Star Ø Design with the Future in Mind - Do we seek Sustainability or other Future Goals?

OSH Management System Models Ø OSHA VPP ä integrates well with NIOSH standards ä simple framework Ø AIHA OSH Management Systems Guidelines ä incorporates JHA model ä robust framework - minimal design decisions Ø BSi 8800 ä aligns with ISO 14001 ä provides HSE guidance ä state of the art model - maximum design flexibility

EHSMS Principles - 2 Ø Practical Integration Issues äWorkforce sophistication äExisting management structure äDelegation (not assignment) of responsibility äImplementation Scheduling äRegistrar management äMaintenance of the EHSMS

EHSMS Design Concepts Ø An EHSMS will deliver precisely what it is designed to deliver - nothing more, nothing less Ø Design must be active and begin at project inception - a direct analogy to product design Ø The E(HS)MS as a Product ä Must meet customer expectation ä Must be marketed ä Must be delivered on time and on budget ä The real value is in the use, not the delivery ä The product must be stewarded throughout its lifecycle

EHSMS Design Concepts - 2 Ø Customer Design Issues Ø Marketing Issues Ø Delivery Issues Ø Eco-Efficiency and the EMS Ø E(HS)MS Stewardship Ø The Principle of Sustainability

Eco-Efficiency - The Master Metric Ø Existing Terms of Limited Value ä Compliance ä EH&S “Performance” ä “Strategic” EH&S Management Ø The New Lodestar - Eco-Efficiency ä 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 ä 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 EHSMS Ø Leadership ä Industry/Corporate/Site/Community Ø Education ä Workforce/Customers/Suppliers/Community Ø Trust ä Installing Wiring for Stakeholder Input Ø Organizational Reinvention ä Fundamental Business Need ä EHSMS is a reinvention engine (in the programme) Ø Sustainability ä Retuning the EHSMS to Dial in the SMS

The WDC EHSMS Vision and Mission Ø WDC EH&S Vision ä WDC 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 Ø WDC EH&S Mission ä Minimize EH&S risks and impacts while optimizing operational efficiency through commitments to P 2, legal compliance, and continuous improvement

The WDC EHSMS Vision and Mission - 2 Ø Vision Document äAligns with Policy Statement äGives clear direction for management review äArticulates clear basis for programme Ø Mission Document äAligns with Objectives äProvides grounding for executive and employee performance reviews äIntegrates into MDs’ business plans

The WDC Implementation Path Ø Initial Review - follows EMAS model for maximum impact in design and manufacturing phases Ø Modeling of QMS - to optimize integration and improve QMS through the implementation process Ø Learning Organization Model - to utilize each education session as an opportunity for continuous improvement

WDC Implementation Santa Clara, California Ø Challenges ä size of site ä manufacturing process ä MD management style - “hands-off” ä history of program implementation ä position in manufacturing cycle (media facility) Ø Opportunities/Solutions ä expand EHS criteria ä redesign opportunities ä inclusion of more middle managers ä monthly milestones gain interest/buy-in ä include core business metric in EHSMS objective set

WDC Implementation Kuala Lumpur, Malaysia Ø Challenges ä number/literacy of workers ä complexity/variety of processes ä number/variety of functions ä personality of EMR ä growth of site Ø Opportunities/Solutions ä MD loyalty and leadership/expanded training ä increase in metrics, not criteria ä allow aspects and ranking to involve more input, time ä EHSMS becomes planning tool

EHSMS Design Consequences Ø Intervention with Financial Partners Ø Intervention with Regulators Ø Commitment to Continuous Off-Line, Non. Production Education of Employees + Key Alliance Partners (the Learning Organization expands)

EHSMS Design Consequences - 2 Ø Share (Internally and Externally) Innovations and Successes of Divisions or Sites to Inspire Others ä Taking and Sharing Credit Ø Hard wiring EH&S Quality Performance to Performance Reviews and Compensation ä Top-down model Ø Tap Creativity of Work. Force, Solicit Participation to Inspire Creativity, and Reward Creativity When Displayed ä Cultural and Financial Challenge - requires “plowing back”

Stabilizing the EHSMS Ø Continuously Learn and Synthesize New Learning ä 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? ” Ø Stage II EHSMS Programs ä ä ä Regulatory Reinvention Life Cycle Inventory Supplier Management Community Outreach/Environmental Reporting Migrating Toward Sustainability

Lessons Learned and the Road Forward Ø Efficiency in Design - align objectives with metrics to show quick returns Ø Accuracy in Design - requires mapping of the manufacturing process Ø Innovation in Design - the value of the Learning Organization Model Ø Eco-efficiency - the opportunities for regulatory reform Ø Challenges - regulatory reform and supplier management

Discussion: Future Challenges Ø Entry of Competition Ø Revisions to ISO 14001/14004 Ø New Technologies Ø New Geographies Ø Others? ?

Edward L. Quevedo Pillsbury Madison & Sutro LLP Environment & Land Use Group San Francisco: 415. 983. 1125 Silicon Valley: 650. 233. 4766 __________ quevedo_el@pillsburylaw. com http: //pillsburylaw. com __________ San Francisco Sacramento Silicon Valley Los Angeles Orange County Carmel Valley San Diego New York City Northern Virginia Washington, D. C Tokyo