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 Data does not include AT&T operations in Latin America or WarnerMedia, except that 2020–2021 data includes select Warner Bros. locations. DIRECTV data is included through July 31, 2021. Note: In July 2021, we completed a transaction with TPG Capital involving our North America video business – including DIRECTV, AT&T TV and U-verse – to form a new company called DIRECTV.
2 These incidents are employee injuries and illnesses that are required to be documented on the OSHA 300 log.
3 These incidents are employee injuries and illnesses that are required to be promptly reported directly to OSHA.
4 These employee health/safety regulatory incidents include government inspections and other agency inquiries requiring a response (e.g., inquiries via phone, fax or mail).
5 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 7 incidents were converted to long-term remediation events.
6 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 2 incidents were converted to long-term remediation events.
7 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 3 incidents were converted to long-term remediation events.
8 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 1 incident was converted to a long-term remediation event.
9 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. None of these incidents was converted to a long-term remediation event.
We take EHS stewardship seriously and are committed to following the most stringent environmental compliance laws and regulations applicable to our operations and the jurisdictions where we work. Due to the complex nature of our operations, the content of this issue brief will reflect AT&T Communications unless otherwise noted.
EHS considerations, such as minimizing and recycling waste, are integrated into our business processes to conserve the natural resources we use and to promote pollution prevention. We also encourage our suppliers to integrate EHS considerations into their processes through our contract language and our requirement that suppliers adhere to the AT&T Principles of Conduct for Suppliers. To learn more, read the AT&T Environment, Health & Safety Policy as well as our Responsible Supply Chain and Waste Management issue briefs.
The AT&T Code of Business Conduct (COBC) outlines our commitment to maintaining a safe and healthy work environment. Each employee – from our part-time workers to our CEO – is responsible for reviewing their respective code annually and understanding its provisions. For more information, see the Our Corporate Governance issue brief.
We train employees on the use of EHS systems relevant to their job responsibilities. Additionally, we provide specialized training and job aids based on job tasks and the hazards an employee is likely to encounter in their position. And we’ve implemented a training matrix to ensure that all employees receive health and safety training commensurate with their roles and at appropriate frequencies. Records for completion of required training are captured for each employee in the corporate Learning Management System.
We evaluate our EHS performance through regular reviews and internal assessments of our operations. The frequency of these assessments depends on the level of risk identified after evaluating the potential for personal injury, property damage, and community or financial impact. AT&T Communications internally audited the Environment, Health and Safety Management System covering 100% of its domestic operations in 2017. In 2021, we completed an internal audit of the Incident Management and Document Controls portions of the system.
Environment, Health and Safety Inspection
AT&T Communications also performed more than 380,000 internal health and safety observations and competency checks in 2021. The subject and frequency of these reviews are based on risks and established through annual, department-specific EHS plans and targets focusing on groups that have the greatest opportunity for improvement. Corporate EHS monitors the effectiveness of these department-specific plans, and targets and works with each business unit to drive improvement.
AT&T Communications completed 3,420 internal Environmental Site Assessments (ESAs) at 2,957 locations in 2021. ESAs are focused on compliance with environmental regulations, such as hazardous material storage and air emissions. We use a risk-based approach to determine the locations and frequency of ESAs. When issues are identified through these inspections or other means, we partner with external organizations or agencies as necessary to reach resolutions that are in the best interest of the environment, our customers and our communities.
See our Waste Management issue brief for more information on our operational waste reduction efforts.
Environment, Health & Safety Management System
AT&T adopted an Environment, Health and Safety Management System for AT&T Communications based on the principles of the standards known as 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 EHS programs and their effectiveness. A comprehensive external review of our system is underway. We have elected not to seek certification by ISO 14001 or OHSAS 18001 at any AT&T Communications locations, based on our cost-benefit analysis. 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 achieving them – are incorporated into each business unit’s annual EHS plan. Progress 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 us 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, 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 & Safety Policy: The AT&T Environment, Health & Safety Policy reflects our responsibility to comply with EHS laws and regulations, continually improve our management systems, and achieve other nonregulatory EHS goals. This policy commits all AT&T business units and operating companies worldwide to operate in an environmentally responsible manner and to protect the health and safety of our employees and the public. We updated the policy in 2020 to include WarnerMedia and Xandr12 and to further align the policy with the evolving needs of our business. The policy update was also informed by external sources, such as the Dow Jones Sustainability Index, that help identify best practices across industries.
- Planning: We identify the potential hazards, risks and impacts to the environment associated with our operations. When new processes or tasks are identified, an EHS professional with knowledge of the work activity performs a hazard assessment and determines 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. Our Business Continuity Preparedness Handbook provides an overview of best practices to facilitate proactive planning and ongoing enforcement for all event scenarios. We maintain assessment results in an online system that helps us design and prioritize programs and processes to prevent or mitigate the potential hazards and risks identified. As part of our planning, we establish objectives and targets to evaluate EHS performance. We manage compliance through a management of change process as well as implementing business unit EHS plans and analyzing audit and assessment data.
- Implementation & Operation: We implement EHS plans by setting targets and deadlines, 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. When incidents or nonconformities with laws or company standards are identified, we have formal systems established to identify corrective actions and 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.
We ensure that safety and environmental responsibility are part of every employee’s standard operating procedure by:
- Training employees on potential health issues, prevention measures, and emergencies through internal and external seminars. We track the number of hours our employees spend on training and set targets for continual improvement.
- 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. This includes providing employees with resources and information on best practices to prevent workplace exposure to COVID-19 and other transmittable diseases.
- 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.
If an accident occurs in the workplace, our policy is to respond swiftly, investigate contributing factors, determine the root cause and take appropriate corrective actions. All employees have access to the EHS hotline, where they are required to report all alleged work-related injuries, illnesses and accidents. Employees are also encouraged to call our hotline to report unsafe work conditions or inquire about health or safety issues.
AT&T Communications had 5 work-related incidents that resulted in fatalities, 1,341 incidents resulting in lost time, and 277 incidents that resulted in job restrictions. In 2021, our Lost Workday case rate was 0.83.
All significant injuries and fatalities are automatically routed to AT&T Corporate EHS Field Support for investigation, analysis and subsequent development of a corrective action plan if certain qualifying factors are identified during the investigation. The analysis identifies key contributing factors and assigns interventions at varying levels (e.g., local, organizational, or policy-related) to prevent the recurrence of similar incidents.