Every year, IBM’s manufacturing, hardware development and chemical-using research locations and organizations — such as product groups, Real Estate Strategy and Operations, Global Services, Global Logistics, Global Asset Recovery Services, and Global Procurement — complete a comprehensive self-assessment. IBM’s Corporate Internal Audit organization may also conduct environmental, health and safety audits. Audit and self-assessment results are communicated to top management. Follow-up, accountability and closure of actions are clearly delineated.
In addition, independent audits are conducted as part of IBM’s single, global registration to the ISO 14001 standard. Approximately 25 IBM locations and relevant business organizations (known as registered entities) are audited annually by an external ISO 14001 registrar. Our manufacturing, hardware development, chemical-using research locations and other registered entities are audited by the ISO 14001 registrar on a 12- to 30-month cycle.
As an integral part of IBM’s global environmental management system, the ISO 14001 registrar also audits IBM’s energy management program and the enterprise-wide database for recording and managing energy information (e.g., consumption, conservation, renewable electricity purchases) against the ISO 50001 standard on energy management systems. Annually, between six and eight of our ISO 14001 registered entities are audited for conformance to the ISO 50001 standard.
On an annual basis, using a sampling approach, the registrar audits IBM’s ISO 14001 registered entities covering 15 to 30 percent of IBM’s global annual energy consumption. During these audits, the auditor tests energy consumption records in the enterprise-wide database, comparing the consumption values on the energy bill to the database entries, determining the accuracy of reported savings from energy conservation projects, and verifying that IBM’s energy management program requirements are being implemented consistently. The results of this testing are used as inputs for a separate, third-party validation audit of IBM’s corporate greenhouse gas emissions management and reporting process. The results of the latest audits can be found on the IBM environmental reporting, disclosure and verification webpage.
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 applicable legal reporting requirements, and every event meeting IBM’s reporting criteria must be reported through the EIRS. Each IBM location must have a documented incident prevention program (including provisions for preventing environmental incidents or their recurrence) and reporting procedure. In 2016, seven accidental releases of substances to the environment related to IBM operations were reported through the EIRS — three releases to air and four to land.
Emissions to air were two releases of refrigerants due to minor leaks in refrigeration systems and one release of propane due to a leak in a piping system. Releases to land were one release of sanitary wastewater, one release of steam condensate, one release of antifreeze, and one release of cooling-tower water. The root causes were 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 proactive approach to pollution prevention and environmental performance is its record of fines and penalties. In 2016, IBM received 61 agency inspections at facilities worldwide with no resulting fines or penalties. Over the past five years, IBM has paid seven fines totaling $81,939.
Fines and penalties worldwide
($ in thousands)