Author Archives: Justin Smulison

About Justin Smulison

Justin Smulison is the business content manager at RIMS and the host of RIMScast, the society's weekly podcast.
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RIMS Membership Has a Say in COSO’s New ERM Framework

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When Risk & Insurance Management Society (RIMS) members use the new ERM framework published Sept. 6 by the Committee of Sponsoring Organizations of theTreadway Commission (COSO), they may recognize their own ideas prominently displayed. Carol Fox, RIMS vice president of strategic initiatives announced the call for public comment on Risk Management Monitor in June 2016. She said feedback from the industry, and particularly RIMS members, is reflected in COSO’s ERM Framework: Integrating with Strategy and Performance.

“RIMS members took advantage of the unique opportunity to influence one of the industry’s major guidance documents. For several weeks, members collaborated and drafted a response, which was publicly available through the end of last year,” said Fox, who participated on the project’s advisory council. “We were very appreciative that COSO reached out to RIMS and other professional associations, whose input strengthened the content, ideas and approaches featured in Integrating with Strategy and Performance.”

A summary of the public comment feedback includes:

  • More than 200 responses–double that of the internal control update
  • Over 70% of responses from individuals
  • Over 50% of participation outside of North America
  • Almost 50% had affiliations beyond COSO memberships
  • Almost 50% of respondents had 10 or more years of risk management experience
  • Positive ratings outnumbered negative ratings by 4.5 to 1

The new publication serves as an update to 2004’s Enterprise Risk Management – Integrated Framework, which is internationally regarded as the standard for applied risk management frameworks. Developed by PwC under the direction of the COSO Board, its simple, five-component structure considers various viewpoints and operating structures while highlighting the importance of enterprise risk management in strategic planning. It also emphasizes embedding ERM throughout an organization, as risk influences strategy and performance throughout the organization.

“The complexity of risk has changed, new risks have emerged, and both boards and executives have enhanced their awareness and oversight of enterprise risk management while asking for improved risk reporting,” said COSO Chair Robert B. Hirth Jr. “Our overall goal is to continue to encourage a risk-conscious culture.”

Enterprise Risk Management: Integrating with Strategy and Performance is available in printed form, e-book, on-line subscription and pdf licensing for large organizations, accounting and consulting firms. Additionally, COSO is planning for the framework to be translated into several languages, including Chinese, Japanese, Spanish and French.

Visit www.coso.org for purchase information and for a link to the framework’s executive summary.

Post-Harvey Lessons For Chemical Plant Managers

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One of the many hazards exposed by Hurricane Harvey occurred in Crosby, Texas, when the Arkema chemical plant suffered fires and small explosions on Aug. 31 and Sept. 1. Floodwaters caused the fires by penetrating the facility and shutting down the cooling systems designed to stabilize 500,000 pounds of highly flammable materials inside. This ultimately caused a mandatory evacuation for all residents within a 1.5-mile radius of the plant. Local news outlets reported that Arkema had no plan in place for six feet of flooding and its last risk assessment was submitted in 2013.

With Hurricane Irma being tracked at 175 miles per hour in the Caribbean, it is possible that chemical plants in the path of destruction—including Florida and the southeastern United States—may face a similar scenario. Regardless of the location of your plant, here are some tips that can help reduce potential business interruption and physical injury during a major natural disaster:

Update your risk assessment. Use Harvey as a catalyst to revisit your risk assessment, especially since new information has emerged about the potential for natural hazards or disasters that can trigger a chemical accident. As recently discussed, the best assessments do more than just feature a column of checked boxes to achieve an organization’s objectives and mitigate business interruption.

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“They prioritize top risks, assign risk ownership, and most critically, integrate risk management and accountability into front line business decision-making,” says Dean Simone, PWC’s U.

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S., Asia-Pacific, and Americas Cluster Risk Assurance Leader.

Submit the assessment to the EPA or other government-appointed body, like your state’s Commission on Environmental Quality. Your facility needs to be able to withstand significant damage to prevent further incidents and public harm. The feedback will hopefully provide some useful criticism to ensure public safety and business continuity.

According to ABC’s Houston affiliate:

In at least one of Arkema’s hazard mitigation plans filed with the federal government, plant officials acknowledged that flooding is a risk. The site sits in a FEMA “high-risk” floodplain that has flooded in the past, leading to a power failure. That time, the site only had six inches of water, a former plant worker said.

It was later revealed in an internal company timeline of events that Arkema did not move temperature-sensitive chemicals via refrigerated trucks and instead banked on its two backup systems, which failed. It seems certain that Arkema will have to consider at least six feet of floodwater when it revises its plan.

Institute an emergency plant management system. This may be included in your company’s risk assessment, and it is important that your employees also know the protocol when it comes to disaster prevention. This includes establishing the lines of authority and communication while on-site and during a catastrophe. OSHA provides guidance for chemical plant management in the event of a mass disaster.

Develop public-facing communications plans. Your communications team, led by an executive officer, should have advisory plans in place in anticipation of, during and following an emergency. The good news is that you don’t have to draft them from scratch. The Centers for Disease Control and Prevention (CDC) offers communications worksheets, templates and guides dedicated to water, sanitation and hygiene-related emergencies and outbreaks. You can customize these documents to reflect your organization’s capabilities and to alert nearby residents and businesses.

Be sure to issue advisories through all possible outlets, including social media. One thing Arkema did correctly was send press releases, incident statements and alerts via Twitter in addition to traditional outlets in order to keep as many people informed as possible.

Communicate with local authorities and emergency workers. All energy plants impact their local communities, surrounding areas and ecosystems. Your company’s hazard plans should be communicated to local fire and police departments and hospitals. This ensures that emergency workers know the potential dangers your plant faces in the event of a disaster and the steps you plan to take to mitigate them.

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Ensuring Your Company’s Disaster Relief Donations Are Well Received

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With Hurricane Harvey’s effects being felt in Texas and Louisiana for some time to come, businesses may want to help victims by making corporate donations. Corporate decision-makers should carefully consider ways to contribute, since some recent post-disaster efforts have not helped as intended.

Depending on your industry and your company’s size, you may have access to supplies or a service that will be useful to victims and aid workers. The New York Times recently listed the local organizations that will accept certain donations. Your efforts can be coordinated with an accredited organization or the local government to determine whether your donations qualify.

Risk management and insurance professionals who would like to help Harvey victims directly can visit the Insurance Industry Charitable Foundation’s (IICF) IICF Hurricane Harvey Disaster Relief Fund. The fund was established in response to a surge of inquiries from its community as to how it can help. The fund has already received $80,000 in commitments, and the IICF will forward all contributions to local nonprofits assisting victims in the area, including the American Red Cross and specifically its Hurricane Harvey disaster fund.

During catastrophes, experts generally encourage these sorts of finance-based efforts in lieu of sending tangible items without a partnership with a local non-profit. Many organizations suggest that it is best to let the aid workers on the ground use their allocated funds to get necessity items like water, toiletries and food. In its Tips For Giving In Times Of Crisis page, CharityNavigator.org dissuades companies from sending supplies ad hoc:

“[This] type of philanthropy is simply not practical or efficient. Even if mail could get to an impacted region, no one is set up to receive these goods, much less organize and distribute them to the victims.”

It has been well documented that donations of tangible items – especially used ones – can cause unintended problems. Some never reach those in need and eventually wind up in landfills; and certain used clothes, like old shoes and Halloween costumes, might insult survivors.

According to Kansas disaster response coordinator Hollie Tapley, about 75% of donated goods will go to waste despite the donors’ good intentions. “Money is the best way because we know culturally what people need,” Tapley told Kansas State Network before Harvey hit Texas. “One group needs something totally different than another group.”

Blood donations are always in high demand following a disaster and national blood banks sometimes hold emergency drives to allocate blood to the affected areas, which might not have the resources to hold their own. If you are determined to reach the affected area, confirm those details with the donation center’s organizer. Bloodsource’s donation locations can be found on the group’s website. The Red Cross also provides information for potential donors online.

RIMS Survey Reveals Continued Confidence in Cyber Insurance

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Cyber insurance is still a priority for risk professionals and stand-alone policies continue to gain international prominence, according to the 2017 RIMS Cyber Survey.

The survey’s 288 respondents represented industries ranging from financial services, government and non-profit and manufacturing to retail, health care and more.

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Based on survey insights it is clear that cyber exposure is a primary concern, with nearly half of respondents confirming they are spending more now than they did last year to protect against it. The most alarming elements of risk continue to include business interruption and its consequent expenses, reputational harm, and notification and response costs. In light of recent ransomware attacks, 72% indicated that cyber extortion is also an important and growing first-party exposure their organizations are facing—a 9% increase from 2016.
Key findings from this year’s RIMS Cyber Survey include:

  • Organizations with a stand-alone cyber insurance policy increased 3% (to 83%) from 2016.
  • Of the organizations without a stand-alone cyber policy, 84% indicated that other insurance policies include cyber liability coverage.
  • Nearly three-quarters (72%) of respondents transfer cyber exposures to a third-party (up 3% from 2016).
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  • Only 34% of respondents thought that the government should mandate cybersecurity standards.

With 61% of respondents considering purchasing cyber coverage in the next two years, it is likely the industry will continue to see slow-but-steady growth.

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But with 83% of respondents reporting that their companies have stand-alone cyber insurance policies, up 3% from 2016, the survey suggests that the market for these policies may be nearing maturity.

“At any given moment, cyber predators can unleash a new hack to infiltrate an organization’s system, steal or lock critical data and cause significant business interruption damages,” said RIMS President Nowell Seaman. “RIMS Cyber Survey shows that risk professionals continue to invest in cyber insurance products and must work in tandem with their insurers and IT professionals to help develop innovative and adaptable solutions for the next generation of cyber threats.”