This post poses the question whether or not reporting is a waste of time and then continues by showing three varying examples of where the GRI reporting is incomplete in very important ways and does not include critical data that is needed in order for the report to give a clear and actual picture of what kinds of waste are being generated and how they are being handled (or not handled). Elaine concludes by providing an example of what she feels is a GRI report, by Vestas, that provides clear numbers, clear narrative, clear graphics, clear reporting, in conformance with EN22 performance indicator.

by Elaine Cohen, Joint CEO of BeyondBusiness Ltd. Read Elaine’s blog. Follow Elaine on Twitter. Elaine is the author of CSR for HR: A necessary partnership for advancing responsible business practices

One of the biggest issues, I believe, in GRI-based reporting is that of comparability, which is the ability to compare performance across companies. Included in the ambitious vision of the GRI was the aspiration to become a platform to enable company and sector comparisons of key sustainability performance metrics. Whilst on a broad scale, some degree of comparability is possible with companies who report with a high level of transparency, there still remain vast gaps in the quality of reporting against individual indicators. Because the GRI check is limited only to a sampling of indicators reported, these gaps are not necessarily picked up by the GRI application level check.
To explain how this shows up in different reports, I took a look at Performance Indicator EN22 which is all about something we all create (ha-ha some more than others): waste. The GRI indicator requests details of hazardous and non-hazardous waste created by the organization’s operations by disposal method, reported in tonnes. Companies are asked not only to detail what they waste but also what they do with their waste. This is as important to the financial sustainability of the company (waste is money) as it is to the sustainability of our environment. It sounds like a fairly simple thing to report, right ? Well, perhaps not.

Arizona Chemicals Sustainability Report 2009
First report from this company, published in 2011, GRI Application Level B GRI Checked. This company has published a printed report summary. The GRI index appears online only. Indicator EN22 is noted as fully reported. In the summary report, we learn that Arizona generated approximately 2.5 million pounds of hazardous waste in the USA in 2009 and less than 10 million pounds in Europe. Over 98% of hazardous waste is sent for off-site incineration and the remaining waste at 2% is landfilled or recycled as required by law. Solid waste, which is not hazardous, is landfilled (80%), incinerated (13%) and recycled (3%). And that’s it. Total amount of waste is not reported, I have to really search for the relevant data and also do some number-crunching to understand their hazardous waste levels in tonnes, and frankly, I really have no idea exactly how much this company is sending to landfill each year. EN22 is not reported in full.

Hoffmann la Roche Annual Report 2010
GRI Application Level A+, third party checked and GRI Checked. This report is an annual report which also confirms to GRI A+ Application Level. The GRI Index is a PDF which has to be downloaded separately and not part of the printed report. Indicator EN22 is noted as fully reported. In the printed report, we learn that Hoffman La Roche generates waste to landfill (inert waste 1,226 tons; construction waste, 14,900 tons; reactor waste 7,208 tons) and separately we are told that the organization generates 27,249 tonnes of general waste and 29,020 tonnes of chemical waste. Now, it gets more complicated. The PDF download GRI Index also has embedded downloads, such as this one one the subject of waste. In this third download, we are told that 95% of chemical waste was incinerated and the rest was landfilled. Then there’s this: In addition, 4279 metric tons of residual substances could be sold as valorised socondary products. Another 16,369 metric tons consisting of mainly solvents were recycled. As regards general waste, 19% of the 27,429 metric tons noted above were incinerated and the rest landfilled. 14,900 tons of this was rubbish from demolished buildings. In addition, 92,141 metric tons of residual materials were recycled. So, by this time, I am totally confused. Is Hoffman’s total waste 1,226 PLUS 14,900 PLUS 7,208 PLUS 29,020 PLUS 4,279 PLUS 16,360 PLUS 27,429 PLUS 92,141 =192,563 tonnes ? How much of this total waste, whatever total means, is hazardous ? The report does not distinguish between hazardous and non hazardous. In addition to having to download three documents, try to make sense of non-sensical figures and add everything up myself, I still remain perplexed as to the total waste levels of this company, despite their pride at having reduced waste levels, so they say, during the past five years. Here we have an A+ report checked by two separate external parties, and I can’t even get a simple figure such as total waste. EN22 is not reported in full.

UltraTech Cement Company, India
This is an Application B+ level report, checked by the GRI. In this report, the GRI Index is part of the report (whew!) and EN22 is noted as fully reported. And lo and behold! We have data. See this:
1103 Ultratech cement EN22
Here we have clear reporting. Hazardous and Non-Hazardous waste separately recorded, split by type and tonnage. Great. Now, where did all those millions of tonnes of waste end up? Oops. Who knows? This is not reported, as far as I can tell. So, all in all, whilst I have a much easier time getting to clear numbers about waste generation, I still do not know how the Company manages waste disposal and Indicator EN22 is not fully reported.

How should Companies report this indicator?

Let take a cue from Vestas Sustainability Report for 2010
Clear numbers, clear narrative, clear graphics, clear reporting, in conformance with EN22 performance indicator. At a glance, we know how much waste, the split between hazardous and non-hazardous, and what happened to it. Well done Vestas!
1103 vestas en22 narrative
1103 vestas waste en22

So, at least there may be light at the end of the tunnel, as one out of four reports I randomly reviewed appears to be able to get it right. As I often say, the GRI guidelines are good. The problem we have is adherence to the GRI guidelines in a rigourous way. Despite checks and verifications, comparability evades us because reporting companies are not applying the correct degree of rigour in their reporting. What’s worse, they are telling us that they are. In the meantime, therefore, let’s not add to overall waste levels by making reporting waste a waste of time, as time, as we all know, is one of the most valuable non-renewable resources of all.

© 2011, Elaine_Cohen. All rights reserved. Do not republish.

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Author: Elaine_Cohen (19 Articles)

Elaine Cohen is the Joint CEO of BeyondBusiness Ltd, a leading CSR consulting and reporting firm, offering a wide range of consulting services for the strategic development of social and environmental responsibility of businesses, reporting and assurance using the GRI and Accountability frameworks, and reporting on application of Global Compact principles. Elaine writes a blog on CSR reporting, expert CSR report reviews for ,tweets on CSR topics at @elainecohen and has specialist knowledge of governance, ethics, diversity, advancement of women, responsible workplace and use of social media for csr communications.

  • Michelle Bernhart

    Well done, Elaine. I agree that comparability is one of GRI’s most noble goals, but like so many of the others (context, anyone?), the complexity of the issues and companies’ struggles to truly follow the guidance make truly direct comparisons all but impossible.

    The waste situation is pretty confusing, as you noted, but if you really want to make your head spin, try comparing water performance across various reporters. Some report in great detail by source in conformance with EN8 (municipal water, well water, etc.), while others report by usage (cooling water, water for steam, water for cleaning, water recycled, and so on). Sometimes the amounts reported as withdrawn, used, and discharged don’t align mathematically, and even among A+ reporters, few do a thorough job of discussing water bodies affected by their operations/withdrawals/discharges (EN9 and EN25). I develop reports and know how hard it can be to get the data right, but it does worry me that the application levels mislead too many readers into thinking that GRI reports of the same application level will be comparable from one to the next. This is far from the case today.


  • elaine cohen

    hi michelle, agree and agree and agree! Everyone believes that a report is complete and transparent by virtue of being an A. But this is often far from being the case. Yes, I know the problems with water reporting too!!
    warm regards, elaine

  • Walker

    Great report, Elaine. I applaud the level of rigor and analysis you bring to this important issue. I completely agree that one of the purported/expected values of GRI is the comparability issue.
    I do, however, disagree with your last sentiment “by making reporting waste a waste of time”. Even if the companies’ reports did not match up to the clarity of Vestas’ report, they should still be encouraged for doing GRI reporting at all. Far too many companies don’t even bother doing any sustainability reporting. I can forgive a company whose GRI report is not ideal if they gave it their best effort. If the report doesn’t live up to expectations, there needs to be a audit / review committee which can provide “lessons learned” to them so that, the next year, their report improves as needed. But even as reported in your article with the lack of aggregated totals, I would not call their output a “waste of time”.

  • elaine cohen

    hello Walker, thanks for reading and commenting. You are completely correct. I agree with you that the challenges of reporting to GRI standards are significant, and the attempt deserves regcognition. However, what invariably is the case here, is that companies have the data or most of the data. The issue is declaring that they are reporting in line with the GRI framework when in fact they have not reviewed the reporting indicator protocolas and aligned the presentation of the data with the GRI standard. Whilst all reporters should indeed be commended, I do believe we should get tougher about the quality of reporting and point out where companies are not adhereing to their own voluntarily declared standard of disclosure.
    thanks again, elaine