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 not inclusive of AT&T operations in Latin America or WarnerMedia. 2020 data is inclusive of select Warner Bros. locations.
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 and mail).
5 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 6 incidents were converted to long-term remediation events.
6; All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 7 incidents were converted to long-term remediation events.
7 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 2 incidents were converted to long-term remediation events.
8 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 3 incidents were converted to long-term remediation events.
9 All spills were addressed promptly and cleaned up in accordance with regulatory requirements. 1 incident was converted to a long-term remediation event.
We take our EHS stewardship seriously, and we 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) and WarnerMedia Standards of Business Conduct outline 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 based on job tasks and the hazards an employee is likely to encounter in their position. Our training plan includes job aids, videos, web-based courses and leader-led activities. We have developed and implemented a training matrix to ensure that all employees receive health and safety training commensurate with their roles and at appropriate frequencies. Attainment of training requirements is 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 and financial impact. AT&T Communications internally audited the Environmental Management System covering 100% of its operations in 2017. We are in the process of completing another internal audit, which is expected to be finished in 2021.
AT&T Communications also performed more than 1,000 internal health and safety inspections and competency checks in 2020. The subject and frequency of these reviews are based on risks and established through annual, department-specific EHS plans and targets. In a typical year, we review a representative sample of departments to ensure alignment with our Environment, Health & Safety Policy, focusing on groups that have the greatest opportunity for improvement, and monitor the effectiveness of their plans and targets. In 2020, we canceled these reviews due to the COVID-19 pandemic and intend to resume them in the following fiscal year. Despite the pandemic, AT&T Communications was able to complete 4,571 Environmental Site Assessments (ESA) at 3,971 locations in 2020. We use a risk-based approach to determine the locations and frequency of ESAs. 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.
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 get answers about health or safety issues.
The combined 2020 Occupational Safety and Health Administration (OSHA) total recordable occupational injury and illness rate for AT&T Communications and Warner Bros. Studio operations was 1.16 per 100 employees.
- For AT&T Communications' U.S. operations, our 2020 OSHA total recordable occupational injury and illness rate was 1.16 per 100 employees. This rate is lower than the most recent (2019) average published by the Bureau of Labor Statistics for the telecommunications industry, which was 2.3 per 100 employees. 12 12 U.S. Bureau of Labor Statistics, https://www.bls.gov/iag/tgs/iag517.htm.
- For Warner Bros. Studio operations, our 2020 total recordable injury and illness rate was 2.33 per 100 employees. The most recent (2019) average published by the Bureau of Labor Statistics for the motion picture and video industry was 1.8 per 100 employees. 13 13 U.S. Bureau of Labor Statistics, https://www.bls.gov/web/osh/summ1_00.htm.
AT&T Communications had 1 work-related injury that resulted in a fatality and 1,381 work-related injuries that resulted in lost time, job restrictions or transfer. In 2020, our Days Away, Restricted or Transferred (DART) rate was 0.88.
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.
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.
Safety at WarnerMedia
Given the transitory nature of media production work, major studios across the industry collaborate on a standardized training program for union production employees. The studios fund the program through their collective bargaining agreements, and it is managed by the Contract Services Administrative Trust Fund. In Southern California, there are currently dozens of courses for union production employees on topics such as fall protection, aerial work platforms and environmental safety, among others, that employees take based on potential hazards related to their work. Crew members on U.S. productions outside Southern California have access to online and hands-on safety training provided by an industry management-labor Training Trust Fund.
At WB, a Product Safety Representative (PSR) assigned by the Vice President of Safety & Environmental Affairs oversees every television and film production. PSRs review scripts as necessary, provide guidance on stunt and special effects activity, arrange additional safety training, and provide safety equipment. They also advise on remediation of potential hazards, such as lead paint, asbestos and engineering issues, and conduct a detailed safety orientation at the start of every production. If an accident happens during production, the set medic or the employee’s supervisor will complete an accident investigation report.
The WB Vice President of Safety & Environmental Affairs and the Executive Director of Feature Production Safety participate in a monthly Joint Labor Management Safety Committee meeting with the Screen Actors Guild union and management representatives active in industry health and safety. Additionally, representatives from WB’s senior management team and the First Aid, Workers’ Compensation and Human Resources departments hold monthly injury trend analysis meetings to discuss the previous month’s injuries or claims and any remedial actions necessary, such as additional refresher trainings or EHS process reviews.
Environment, Health & Safety Management System
AT&T adopted an Environment, Health and Safety Management System based on the principles of the 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, which we expect to be complete in 2021. 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 non-regulatory 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 Xandr and further align the policy with the evolving needs of our business. The updated policy is also informed by external measures, such as the Dow Jones Sustainability Index, that help us 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 a web-based 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 document. 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.
Additionally, production employees can call Warner Bros.’ Anonymous Safety Hotline to report concerns. The hotline number is listed on all call sheets and posted on location and in soundstages. A safety representative documents and addresses each call, and corrective action(s) or additional training is implemented as necessary.
See our Waste Management issue brief for more information on our operational waste reduction efforts.