Collaborating on Compliance

James Bilgo

For James Bilgo, Supervisor of EHS Program Management for Kohler Co., ensuring regulatory compliance is a unique challenge. A diverse manufacturing and services company, Kohler has more than 80 ‘facilities’ worldwide, including small tractor factories, high-end furniture showrooms, sales offices, spas, hotels and even golf courses. They all share the Kohler name, though, and Bilgo’s auditing team works hard to protect it. We caught up with him this week to talk about the company’s auditing programs and how he helped build a strong compliance culture.


GT: Today, the Kohler Co. is known for its strong culture of compliance. How did your team achieve that?

JB: Going back 25 years ago, we were probably like most companies in that we would go to our operations and spend a week there walking through their facilities and doing what everybody would call your environmental, health and safety (EHS) audit.  We would then write up a report and then walk away.

What we noticed was that we started seeing the same thing, time after time at all our facilities. And we just said, ‘We need to take a different approach to this. We need to be part of their team. We have to build up that comfort level so if they have that problem, we’re the people they think about calling.’

So what we’ve done over the past 20 years is to develop systems that cooperatively and proactively show our operations the path to improvement. We then train them, help them, encourage them, and basically do whatever we can to help them get there.

GT: Can you describe what your inspections are like now?

JB: Today our visits don’t feel like inspections. Our facilities actually ask us, ‘When are you going to come next? We really need you here. We want to show you some of the good things we’re doing; we want to get this next tier level of performance.’

When we walk through a facility now, we don’t walk around and point out problems; we walk around and look at things. And many times, the things that stop us in our tracks are good things.

GT: When there is a problem, what kinds of things do you do to help them solve those problems?

JB: When there is an issue, we try not to just be critical; we want to be very positive. A lot of times we have a discussion, the facility managers make suggestions and we add our expertise about what other plants are doing.

We also have a Web page, where we put all of our best practices and all of the programs we think the facilities should be pursuing.  When someone has done a good job, we put their best practice out there for everybody to look at and share.

Every year, we hold an EHS conference, where we bring in all our EHS people from all of our operations all over the world to share best practices, and figure out how to solve the problems. And when someone does have a problem, we end up sharing the solution with everyone so it’s more of a cooperative effort.

GT: How do you train your team to ensure they provide the right direction to the facilities?

JB: The guys who work for me, very seldom get technical training. I train my people more on how to have a crucial conversation, how to be a leader, how to have emotional intelligence so they can communicate in a very positive way to the operations. That’s a lot of what my guys take to the facility.

Our department has three main purposes. The first is protecting the Kohler brand. It’s very important that when people think of Kohler they think ‘They’re the guys with the really nice golf courses,’ or ‘They’re the guys who make those fantastic bathtubs.’ We want people to think about Kohler and think about great company, great quality.  Two, we want to send all of our associates home in better condition than they were in when they arrived in the morning. And the third is, minimizing the impacts of our operations on the environment and on future generations. So all of our programs are geared to one of those three main objectives and that’s what we tell our operations.

GT: Can you describe how you’ve structured your system?

JB: Ours is a tiered system, in which the facilities are recognized for their achievements.

On the safety side, we developed the Kohler safety management system, a very detailed roadmap for operations to achieve world-class safety performance. We looked at other programs out there, developed our own and distributed it to the facilities. At first, everybody went through it and tried to find the easy things — and not necessarily the right things to do first.

So we found out that we kind of made a mistake there. You’ve got to build. You have to have a good foundation first before you can put on the roof. So we went back and we looked at the whole system, identified our expectations and prioritized the issues. Is this an issue that falls into Tier 1 (compliance); Tier 2 (management commitment); Tier 3 (Has it been adopted by all associates?); or Tier 4 (There’s no reason for us to even come and look at their operation)?

We’ve had this going for eight to ten years and we’re still heading down the path.

GT: What are some of the hallmarks of Tier 4?

JB: To reach Tier 4, the assessment involves going out and interviewing the associates on the floor, asking them questions and seeing how they answer.

What we’re looking for is whether they expound upon their answers and show us more than what we asked.  If so, they’re portraying a positive EHS attitude and demonstrating that by showing us what they’re doing. To reach the highest tier on the environmental side, for example, they should be able to look in the garbage can and say, ‘See? We don’t even need garbage cans here because we don’t throw anything out anymore.’ We’re not there yet, but that’s what you want them to ultimately say.

GT: Do you still have checklists?

JB: We do have an assessment tool that asks specific questions that we confirm through documentation, interview or observation. It then explains what we should specifically be looking for. On Tier 1 it’s mostly show me the documentation; at Tier 4, it’s right to the interview and the observation. Is it very obvious to me that they understand it and they are living it?

GT: How do you ensure they maintain their status?

JB: We have a safety group (outside of our team) that does a complete assessment of the Tier 3 and Tier 4 facilities. Every few years, they will go back and reassess the operation to ensure it is maintaining its status. It’s my team’s responsibility to continue to work with the plant to keep up the good work.


About James Bilgo

James Bilgo is the Supervisor of EHS Program Management for Kohler Co. He discussed the company’s collaborative auditing programs during NAEM’s <a href=""2011 EHS Compliance Excellence” conference in Minneapolis.

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