Audits and Compliance
IBM measures our environmental performance against both external and internal requirements.
Every year, and more frequently for some, IBM’s manufacturing, hardware development and research sites and organizations— such as Product Development, Global Real Estate Operations, Global Asset Recovery Services, Global Logistics, Global Services Environmental Compliance and Integrated Supply Chain—complete a comprehensive self assessment. In addition, IBM’s Corporate Internal Audit staff may conduct environmental, health and safety compliance audits. Audit results are communicated to top management. Follow-up, accountability and actions are clearly delineated.
In addition, as part of IBM’s single, global registration to ISO 14001, approximately 25 sites or registered entities are audited annually by an independent ISO 14001 registrar. The company’s manufacturing, hardware development and chemical-using research sites are audited by either the Corporate Internal Audit team or the external ISO 14001 registrar every 18 to 30 months.
IBM sites around the world report environmental incidents and accidental releases to IBM management through the company’s Environmental Incident Reporting System (EIRS). IBM’s environmental incident reporting criteria are equal to or exceed legal reporting requirements and every event meeting IBM’s reporting criteria must be reported through EIRS. Each IBM location must have a documented incident prevention program (including provisions for preventing environmental incidents or their recurrence) and reporting procedure.
In 2012, a total of 26 accidental releases of substances to the environment related to IBM operations were reported through EIRS. Of these, 12 were to air, seven to land, five to water, and two to both land and water.
Emissions to the air included 10 releases of refrigerants. One emission was smoke resulting from a chemical reaction that took place during cleaning activities (mixing of epoxy resin and hardener) and there was one release of particulate matter.
Releases to land included one each of reclaimed water, fuel oil, cooling tower water, hydraulic fluid, sanitary wastewater, potable water and chilled water.
Releases to water included one each of cooling tower water, chilled water, hot water, water containing a cleaning agent and one lubricant oil.
Releases to both land and water include two releases from treated groundwater.
The root cause was investigated for all releases and corrective actions were taken as appropriate. None of the releases was of a duration or concentration to cause long-term environmental impact.
Fines and Penalties
One significant measure of a company’s environmental performance is its record of fines and penalties.
IBM was the subject of 89 successful environmental regulatory agency inspections and visits worldwide in 2012 with no fines or enforcement measures being assessed associated with those inspections.
IBM did receive three fines, however, related to inspections in previous years. Relating to a 2009 Notice of Violation issued by the Connecticut Department of Environment and Energy Protection, IBM received two fines in 2012 totaling $36,814. The citations were for exceeding the permitted time limit for operating an emergency power generator at a data center and for failure to timely complete the scheduled emissions testing on the emergency generators. The emissions testing was completed after the notification in 2009 and we have since updated our processes to prevent recurrence.
In addition, a fine of $38,000 was paid to the Environment Authority of Portugal related to a 2010 shipment of used electronic products from Portugal to IBM’s product reutilization facility in France. Shipments of used electronic products for recycling within the European Union require permits from both the shipping and receiving countries. In this particular case, the permit for the shipping country (Portugal) had expired the month prior to the shipment and had not yet been renewed. IBM has addressed the issue with its contracted logistics supplier to ensure that proper permits are in place in both shipping and receiving countries prior to any future shipments.
Over the past five years, IBM has paid five fines for a total amount of $104,814.
Fines and Penalties Worldwide($ in thousands)