Funderburg, Lisa, Energizer Holdings, Inc., Vapor Intrusion Update: Good Communication Strategies, 2015 MECC-KC
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A presentation at the 2015 Midwest Environmental Compliance Conference, May 13-14, 2015, Overland Park, KS
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Funderburg, Lisa, Energizer Holdings, Inc., Vapor Intrusion Update: Good Communication Strategies, 2015 MECC-KC
- 1. Vapor Intrusion Update: Good Communication Strategies Lisa A. Funderburg Chief Environmental Health & Safety Counsel, Energizer Holdings, Inc.
- 2. What are key strategies to help effectively manage a VI situation? • Communication • Communication • Communication
- 3. Let’s look at an example: Manufacturing Facility • Self audit Findings: Vapor Degreaser with questionable secondary containment
- 4. Next Steps • Sampling • Discovery of TCE and PCE-affected soil and groundwater beneath floor slab • Findings communicated to State • Press release developed • Conducted a multi-phase site investigation • Employee notifications made at each phase of work
- 5. Vapor Intrusion becomes a Driver • Investigation identifies impacts off site • State expresses concern about potential for vapor intrusion into 12 neighboring residential properties
- 6. Off-Site Investigation • Preparation begins for conducting off-site investigation – public roads, private properties – access agreements • Communication efforts formalized • Senior Management • Communications Firm • Local officials • Media • Residents
- 9. What were the key steps in this process for the lawyers? 1. Issue a Record Hold Notice – What is it? – Purpose?
- 10. Key steps for Lawyers 2. Establish a Privilege Communication Plan – What is it? – Why? – “Front page” test.
- 11. What are the elements of a Privilege Communication Plan? • Need-to-know basis • Communicate verbally if possible
- 12. • Avoid note taking at meetings. • Don’t generate new documents if you can avoid it. • Email communication regarding the situation should be effectively and thoughtfully managed.
- 13. Key Steps for Lawyers 3. Engage a Communications (PR) Firm Really? Really.
- 14. There’s no such thing as bad publicity – really? (The only thing worse than being talked about is not being talked about.) Oscar Wilde
- 16. West Virginia Chemical Spill
- 17. Charleston, WV tap water
- 18. Managing Communications: Fundamental Strategies 1. Facilitate proactive dialogue between your company and the community 2. Create tools for broad use in support of community communications 3. Establish communications framework to support strategy 4. Position company as a good corporate citizen that acts responsibly.
- 19. Rules to Keep In Mind to Optimize Communications: • Don’t confess. • Don’t lie. • Don’t volunteer too much information. • Dragnet rule -- just the facts.
- 20. Tactics • Door-to-door outreach to affected neighbors – By plant manager, HSE manager • Regular communication with other audiences – e.g., State, local officials, media • Media training – Scenarios, role-playing • Communication tools arsenal – Update/refine as developments warrant
- 21. Results • Good working relationships – State, local officials, media • No major issues – Affected neighbors, property owners • Minimal media coverage – Generally neutral/favorable
- 22. Final Key Step? 4. Remember your Boy Scout roots: “Be Prepared”. In fact, be OVER-prepared.