As a science and technology company with manufacturing operations, our activities have an impact on the environment, generating air emissions, wastewater and waste. Even the materials we utilize could adversely affect the environment if not handled properly. To mitigate these impacts, all our sites meet a strict set of environmental regulations and continually adapt their processes to new regulatory requirements. Moreover, due to the growing scarcity of natural resources, we attach great importance to using energy, water and materials efficiently.
Our approach to environmental stewardship
Minimizing negative environmental impacts and taking meaningful climate action requires a holistic approach. Our goal is to diligently monitor detrimental emissions into the air, water and soil and try to prevent them wherever possible.
How we structure our environmental stewardship practices
On October 1, 2018, Belén Garijo took over from Walter Galinat as the Executive Board member with responsibility for environmental governance, a remit that also covers climate impact mitigation, water management, waste and recycling, and plant and process safety. Our Group function Environment, Health, Safety, Security, Quality (EQ) is in charge of steering all related ecological efforts Group-wide. At our individual sites, each site director is responsible for environmental stewardship as well as occupational safety at the operational level. At larger facilities, the site directors receive day-to-day support and advice from Environment, Health and Safety (EHS) managers, with EHS coordinators performing this role at smaller facilities. These local EHS organizations report to and work hand in hand with EQ.
In 2018, our EHS organization comprised more than 200 EHS managers – supported at the local level by other personnel. Our Group function EQ conducts annual EHS seminars at our various sites. All new EHS managers are required to complete EHStart-up!, a three-day training course held at our global headquarters in Darmstadt that covers topics such as our Rapid Incident Report System (RIRS, see below), energy efficiency and climate impact mitigation, wastewater, occupational safety and process safety.
The EQ leadership meets with the Executive Board on a regular basis, usually once a month, to report on their environmental stewardship efforts. Every six months, EQ provides the Executive Board with a report on environmental, health and safety issues that also covers climate impact mitigation, water management, waste and recycling, and plant and process safety. The report focuses on our current progress, documenting and assessing the work EHS has accomplished. The Executive Board utilizes this brief as a source of information and as documentation to support ISO 14001 and BS OHSAS 18001 certification.
Our Executive Board is moreover responsible for approving internal guidelines such as our Environmental, Health and Safety (EHS) Policy. Internal standards are approved by the head of EQ. While standards provide an operational framework, guidelines present an overarching outline of our company’s position on a specific issue.
Our EQ Group function (“Environment, Health, Safety, Security, Quality”)
Responsibilities of Group Governance and Service Unit Environment, Health, Safety, Security, Quality (EQ)
- Develop and maintain Group EG strategy
- Performance of environmental and safety audits
- Compliance audits to review adherence to standards
- Implementation of EQ management systems
- Conducting EQ improvement programs
- Consulting for investments, process development and acquisitions
- Conducting training programs
Responsibilities of local operating units with competencies at local sites:
- Wastewater treatment
- Waste management
- Environmental analysis
- Plant safety
- Occupational health and safety
- Fire protection/risk prevention
- Approval procedures
Clearly defined incident reporting procedures
We have established a variety of reporting procedures (EHS Leading Rate) to review critical situations, near misses and environmental incidents as quickly as possible and take corrective action. These procedures allow us to track the respective incident, its degree of severity and all risk mitigation efforts. All incidents are logged Group-wide and reported to the Executive Board every six months.
In the event of major incidents, our Rapid Incident Report System (RIRS) promptly notifies the Executive Board, our EHS Group function and Group Communications. Such incidents may include fatalities, accidents with multiple casualties, or injuries and damage that occur beyond our premises, but also environmental disasters such as earthquakes or floods. Through the RIRS, we can coordinate the responses of all those involved and inform other potentially impacted sites immediately. To make the RIRS faster and more effective, we migrated to an online version of the system at the end of 2018.
Our commitment: Standards and standard operating procedures
Our approach to environmental stewardship is built on our Group-wide EHS Policy (Corporate Environment, Health and Safety Policy), which has been endorsed by the Executive Board. This policy is closely aligned with the stipulations of the chemical industry’s Responsible Care® Global Charter, as well as with the environmental management standard ISO 14001, and emphasizes the responsibility of our leadership toward environmental stewardship, health and safety. Moreover, it addresses our suppliers, encouraging them to adopt similarly enhanced standards governing environmental sustainability and safety. In doing so, our Corporate EHS Policy complements the Responsible Sourcing Principles of our Group Procurement function.
The principles of our EHS policy are implemented through internal guidelines, standards and standard operating procedures. For instance, our Group EHS, Security and Quality Manual describes how we organize environmental stewardship and occupational safety across the company. In addition to this manual, we have put in place a number of other internal standards that govern environmental stewardship such as our Air Emissions Standard, Waste Management Standard and Energy Management Standard.
Potential EHS risks posed by acquisitions, divestments or site closures are assessed through due diligence, a process defined in our EHS Due Diligence and Post Merger Transaction Standard. During audits, new sites are given priority.
We regularly review our internal guidelines, standards and standard operating procedures. In 2018, we revised and introduced multiple standards and processes. For instance, we updated our Office and Field Service Safety Standard to increase our focus on safety in areas beyond our production facilities. We also adjusted our Occupational Hygiene Standard. In making these improvements, our aim is to better recognize and counteract health hazards in the workplace. In addition to these efforts, in 2018 we introduced the Sustainable Water Management Standard. Composed of two parts, it replaces our Water Protection Standard and details wastewater discharge control and monitoring, water use analysis and protective measures against rainwater risks such as contaminated rainwater.
Material investments in environmental impact mitigation
Preventing and monitoring air, water and soil emissions involves large expenditures on the part of our company, as does proper waste disposal. Moreover, we have set aside provisions for groundwater and soil remediation to ensure our ability to execute all measures required. In 2018, our provisions for environmental impact mitigation totaled € 137 million, 94% of which was attributable to Merck KGaA, Darmstadt, Germany. Neither these environmental indicators nor the ones appearing later on in the report reflect data from our Consumer Health business. This is due to the fact that this business was transferred to Procter & Gamble as of December 1, 2018 and, pursuant to IFRS 5, was classified as a discontinued operation as of April 2018.
Parking lot remediation completed
In 2018, we completed our ten-year project to decontaminate a parking lot at our Gernsheim site. The scope of the environmental remediation required turned out to be significantly greater than originally anticipated. During the decontamination work, we removed hexachlorocyclohexane (HCH) residue from the soil under the parking lot and properly disposed of it using external incinerators.
Assessing environmental impacts and reporting violations
In general, we conduct risk-based assessments along with internal and external audits on all our production facilities every three years with the goal of analyzing and minimizing our environmental footprint. Conducted by EQ, these assessments serve to ensure that our requirements are being met. As needed, we use the results to define a suitable course of action. In addition, grievance mechanisms are in place to identify potential violations of our requirements. In 2018, our corporate EHS audits rated 80% of the 40 sites audited as “good” or “satisfactory”. We assess performance on a five-tier scale: “excellent”, “good”, “satisfactory”, “poor”, and “critical”, which in turn determines how frequently an audit is conducted. If the findings are deemed to be good, a facility will undergo audits less often, while significant violations can increase the frequency.
Aside from using audits to identify issues, we also encourage employees to report potential violations of our standards to our Compliance unit. All of these violations are reported to the Executive Board. In the 2018 period, we recorded no significant violations of environmental laws or regulations Group-wide.
ISO 14001:2015 Group certificate
Since 2009, our company has held a Group ISO 14001 certificate, which means that all production sites with more than 50 employees must implement the requirements of the certificate. Other facilities are not obligated to implement an ISO-certified environmental management system. New sites must gradually establish a corresponding environmental management system with predefined indicators for factors such as greenhouse gas emissions and water use, as well as obtaining ISO 14001 certification. The annual internal audit reports and management reviews carried out as part of the Group certificate afford us a better overview of how all our sites are performing.
of our sites worldwide are currently covered by the ISO 14001 certificate.
Every year we contract a third party to perform a certification audit. In 2018 a sample of ten sites underwent and passed an ISO 14001 audit, while two facilities were newly incorporated into the Group certificate. Furthermore, we conduct internal audits to ensure compliance with our requirements.
By participating in a variety of industry associations, we exchange information and ideas on environmental issues. In 2018, for instance, we took part in discussions between the German Chemical Industry Association e. V. (VCI) and German legislators on eliminating the thermal value criteria. Until the end of 2018, our company chaired the VCI plant safety working group. Additionally, we contribute to the dialogue on plant and process safety in our capacity as a member of the European Process Safety Center and the Commission on Process Safety of the German Federal Ministry for the Environment, Nature Conservation, Building, and Nuclear Safety. Since 2018, we have also been involved in a multi-stakeholder dialogue to develop the Trace Substance Strategy of the German federal government to protect aquatic ecosystems.
Furthermore, we engage residents in the vicinity of our sites in discussions on issues of local relevance.