We are committed to complying with all applicable environment, health and safety laws and regulations, and to maintaining and improving management systems to ensure environmental responsibility and employee safety.
1 These employee health/safety regulatory incidents include government inspections and written inquiries.
2 All spills were addressed promptly and cleaned up in accordance with regulatory requirements; 1 incident was converted to a long-term remediation event.
We are committed to following the most stringent environmental compliance laws and regulations applicable to our operations and to the jurisdictions in which we operate. We also work to integrate EHS considerations into our business processes — encouraging our suppliers to do the same — to conserve the natural resources we use and to promote pollution prevention, including minimizing and recycling waste. To learn more, read our Environment, Health & Safety Policy, signed by our Chairman and CEO.
We train all employees on our EHS system, and we conduct specialized training based on job tasks and the hazards an employee is likely to encounter in his or her position. We have created a training plan that includes job aids, videos, web-based courses and leader-led activities. A training matrix is used to ensure that all employees receive health and safety training at appropriate frequencies and commensurate with their roles. Training progress and compliance is captured for each employee in the Corporate EHS Training Management System.
We take our EHS stewardship seriously, and we evaluate our EHS performance through regular reviews and internal and external audits, the frequency of which depends on the level of risk identified. In 2018, we had 2,220 EHS inspections by government agencies, resulting in 241 violation notices — 5 of which resulted in a penalty, totaling $11,633 in fines paid. In 2018, we also had 104 health/safety government inspections, resulting in 8 violation notices — 3 of which resulted in a penalty, totaling $7,425 in fines paid.
We completed Environmental Site Assessments at 3,143 locations in 2018, selected using a risk-based approach. When issues are identified through these or other means, we partner with organizations or agencies as necessary to reach resolutions that are in the best interest of the environment, our customers and the citizens of our communities.
We require our business units to perform internal health and safety audits in accordance with their specific EHS plans and targets. Through that process, in 2018 we conducted comprehensive reviews on 174 work groups and completed 1,107 safety observations of individual employees.
In 2018, our EHS organization implemented a system in which every significant injury or fatality receives an in-depth investigation by EHS using a Human Factors Analysis and Classification system that identifies the root cause and the human factors that contributed to it. Initial reports will be communicated to employees in 2019.
- Workplace Conditions
We ensure that safety and environmental responsibility become part of every employee’s standard operating procedure, by:
- Encouraging managers to get into the field as often as possible, to engage their teams, promote safety and environmental compliance and correct hazards.
- Setting and communicating expectations that all employees follow established safety rules, regardless of their position or situation.
- Holding teams accountable for creating an engaging environment and supporting employees who want to participate in EHS program development activities.
- Rewarding employees for making good decisions related to EHS, providing transparent and timely communication on progress toward EHS goals, and ensuring business metrics do not result in undesirable behaviors.
- Monitoring performance through regular updates on relevant leading and lagging indicators, including accident data and organizational performance toward meeting targets set in each business unit’s EHS plan.
Through assessment of potential noise exposures, we developed a comprehensive hearing conservation program that consists of audiometric testing and training for employees who have potential exposure to noise levels above regulating agencies’ standards.
AT&T also has a comprehensive program to maintain indoor air quality (IAQ), which involves the maintenance of buildings and ventilation systems, immediate clean-up of water leaks, considerations for temperature and humidity, and standards of care to reduce the introduction of pollutants such as chemicals and smoke in the workplace. An IAQ overview course is available to all employees on demand. AT&T mirrors the American National Standards Institute (ANSI) consensus standard for indoor temperatures, which establishes environmentally-friendly temperature settings and helps ensure the comfort of building occupants.
AT&T maintains a web-based building emergency action plan tool and repository to provide building occupants with emergency response guidelines. For each company-owned or leased building with 11 or more AT&T occupants, an emergency coordinator and emergency site coordinator are assigned to provide emergency preparedness and response functions. For all other buildings, the most senior-level employee or non-payroll worker serves as the “person-in-charge.”
- Environment, Health and Safety Management System
AT&T adopted an Environment, Health and Safety Management System based on the principles of International Standards Organization (ISO) 14001 and Occupational Health and Safety Assessment Series (OHSAS) 18001. This system includes provisions for the planning, implementation, operation, evaluation and annual review of our health and safety programs and their effectiveness. We have elected not to seek certification by ISO 14001 or OSHAS 18001 at any of our locations, based on our evaluation of the costs/benefits. Please see our EHS Certification Comparison Table for our system’s alignment with these standards.
Each year, our EHS team partners with business unit representatives to establish targets for personal injury accident and motor vehicle accident rates, where applicable. These targets — and the strategies for reaching them — are incorporated into the annual EHS plan for each business unit. Progress toward the plan’s targets is reviewed at least quarterly with the business units.
The EHS management system provides a framework for AT&T to systematically manage its environmental risks and health and safety hazards. In doing so, this system helps AT&T improve our operations and performance while maintaining the highest commitment to the health and safety of our employees and protection of our environment.
Developed for AT&T employees, customers and a range of other parties, the EHS management system ensures compliance with external and internal objectives through the following 6 elements:
- General Requirements: As mentioned above, our EHS management system is based on the principles of International Standards Organization (ISO) 14001 and Occupational Health and Safety Assessment Series (OHSAS) 18001.
- Environment, Health and Safety Policy: The AT&T EHS Policy commits to achieving compliance with EHS laws and regulations, continually improving our management systems and achieving other non-regulatory related EHS goals.
- Planning: We identify the potential hazards, risks and impacts to the environment associated with our operations. When new processes or tasks are identified, a hazard assessment is performed, approved and analyzed by an EHS professional with knowledge of the work activity and potential hazards, as well as what personal protective equipment (PPE), if any, should be required. The use of PPE is considered a last line of defense, as first emphasis is given to engineering or administrative controls that can eliminate such a need.
We maintain assessment results in a web-based system that helps us design and prioritize programs and processes to prevent or mitigate the potential hazards and risks identified. Our planning involves establishing objectives and targets for evaluating EHS performance. We also manage compliance by implementing a management of change process, implementing business unit EHS plans and analyzing audit and assessment data.
- Implementation and Operation: We implement EHS plans by assigning clear responsibility and accountability for EHS performance and defining clear roles and responsibilities within the EHS organization. We train AT&T employees and communicate EHS expectations to our vendors and contractors, providing EHS information both within and outside the enterprise.
- Evaluation: AT&T evaluates our EHS performance in varying frequency from monthly to quarterly, depending on the business unit and type of work performed. Our evaluations analyze key performance measures and metrics covering most of AT&T, and review business operations that impact EHS. Monitoring for health and safety performance is outlined in each business unit’s annual EHS plan document. When incidents or nonconformities with laws or company standards are identified, we have formal systems established to identify corrective actions and to track these actions until they are completed.
- Management Review: Senior leadership participates in regular reviews of our EHS performance and programs. The lead for our EHS management system reports to the vice president of real estate operations.
As part of our overall EHS management system, we also maintain a toll-free number (800-KNOW-EHS) for employees to call regarding issues such as hazardous material spills and employee health and safety incidents. Each call is managed by an EHS representative and documented in our EHS Incident Tracking System.
See our Waste Management issue brief for more information on our operational waste reduction efforts.
Since the acquisition of WarnerMedia in June 2018 and the launch of Xandr in September 2018, we are continuing to integrate operationally and through our CSR reporting. For this reason, information for these 2 affiliates is not included in this brief, except where specifically referenced.
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