Why Report Noise Pollution?
Noise pollution is any unwanted or disturbing noise, also known as environmental noise, which can have varying effects. Noise pollution often stems from workplace machinery, loud music, transportation, construction, and wind turbines, to name a few. These harms are also associated with several health conditions including hearing loss, cardiovascular problems, and faster cognitive decline.
To understand the proposed reporting guidance regarding noise pollution, a foundation in the law must first be introduced. The Clean Air Act is a federal law that grants the Environmental Protection Agency (EPA) authority to implement standards to protect public health. Title 42 Section 7641 of the United States Code authorized the establishment of an Office of Noise Abatement and Control to conduct investigations affecting public health to identify and classify sources of noise pollution. As of 2021, as stated in a recently proposed amendment to the bill, “approximately 28,000,000 individuals in the United States are afflicted with some hearing impairment, and it has been estimated that 10,000,000 of those impairments are at least partially attributable to damage from exposure to noise” (Bill Amendment). Noise reduction programs are at the forefront of some lawmakers' minds right now as noise pollution has become increasingly worse.
Given that noise pollution is an ongoing problem that society is trying to reduce, some companies’ stakeholders are asking companies to reduce their noise pollution. Towards this end, many companies are beginning to report and reduce noise outputs as part of their environmental, social, and governance (ESG) efforts.
Exploring the CDSB Framework
The Climate Disclosure Standards Board (CDSB) is an independent organization whose guidance has been consolidated into the International Financial Reporting Standards (IFRS), which allowed for the creation of the International Sustainability Standards Board (ISSB).
Before CDSB’s consolidation, it published a list of requirements to guide companies on ESG reporting. The CDSB’s framework was created to complement financial reporting and to encourage standardization of environmental and social reporting in companies’ mainstream financial reports. While the framework does not require any specific formats or styles to be used, the intention of the CDSB’s framework is to guide companies in creating streamlined and comparable financial reports that are easily digestible for stakeholders. This article will focus on the Reporting Requirement REQ-04 in the guide: Sources of environmental and social impact. The purpose of REQ-04 is to report material sources of environmental and social impact that have arisen over the reporting period using qualitative and quantitative data. The CDSB defines sources of environmental and social impact as activities of and outputs from the organization that have or may have caused or contributed to environmental and social impacts. Some of these activities relating to the environment include greenhouse gas (GHG) emissions, renewable and non-renewable energy consumptions, and non-GHG emissions, particularly noise.
The CDSB recommends that high-quality quantitative information should be supplied for these material sources of impact, and, at a minimum, companies should report where these issues arise from the operations or activities within its organization. An example of quantitative information could be reporting the average decibel output of a manufacturing plant or a plane landing zone relative to the distance of nearby listeners. The CDSB also recommends a narrative that aids the stakeholder in understanding the reported data. If reporting quantitative data is not possible, qualitative information should be given. Since many companies find it more difficult to publish quantitative data, many choose to publish qualitative narratives instead.
Qualitative information should be presented using normalized and accepted statistical methods and should avoid obscuring or misrepresenting the experience of the most at-risk groups.
The CDSB also recommends that sources of environmental and social impact that originate outside the organization’s reporting boundary still be reported when feasible. The CDSB also recognizes that because there is a lack of recognized methodologies for calculating these ESG impacts, things like dialogue, transparency, and information should be given to potentially-affected stakeholders when possible. Most importantly, the CDSB recognizes that most of this information is already collected by organizations because of regulatory agency requirements or other state law requirements.
While a full report of the CDSB framework is beyond the scope of this article, we can see how the framework recommends common sense and streamlined environmental and social reporting be included in financial reports. Many noise producing organizations are already measuring and reducing noise output so as to not harm workers or nearby civilians. The only leap the CDSB asks of these organizations is to make the data digestible and more readily available in financial reports. It is reasonable to believe that this framework will be a reference for the ISSB’s soon-to-be-announced guidelines.
Company Applications and Examples
For non-GHG emissions like noise pollution, it appears (based on the examples below) that stakeholders of noise impact organizations are typically more interested in the social and health consequences of these emissions on civilians and workers than the environmental effects.
While noise producing organizations may not explicitly use the CDSB framework, these companies do publish ESG reports that cover the topic of noise pollution and are in accordance with the CDSB framework. Below are two examples of ESG reports that discuss noise pollution and are in accordance with the CDSB framework.
CNH Industrial 2021 Sustainability Report
CNH Industrial is an equipment and services company that works to sustainably advance the work of agriculture and construction work. To achieve its objectives, the company supplies strategic direction, R&D capabilities, and investments in the agriculture and industrial sectors.
In its thorough 2021 Sustainability Report narrative, CNH Industrial stated that some of the company’s objectives are to reduce its “carbon footprint, improve occupational safety, establish life-cycle thinking, and increase engagement” (Sustainability Report). Among CNH’s occupational safety goals, one goal is for the company to lower noise emissions to combat hearing damage to employees in hazardous environments. CNH also aims to lower noise emissions company-wide because the company classifies noise emissions as a hazardous substance.
Regarding occupational safety, the company goes through lengths to describe qualitative data to stakeholders. For example, the company states the following:
In Italy, the Modena plant implemented several initiatives which led to an improvement in the handling of components in the golden and strike zones, the installation of a new electric screwdriver, a decrease in vibration and noise levels, and a reduction in the manual handling required during assembly.
The Powertrain plant in Córdoba (Argentina) implemented several initiatives, including: the adoption of a new electric torque-controlled screwdriver to remove the Cursor engine’s bearing cover, which also led to lower vibration and noise levels; the introduction of a new, technologically advanced screwdriver to replace the old one; the installation of a clamping system; and the adoption of a motorized hoist to lift components (Sustainability Report).
While there is no concrete quantitative data about the noise and vibration levels being reduced in these plants, describing to stakeholders that the company is making progress on this goal is an important aspect of transparency.
On a company-wide basis, CNH Industrial states that in 2021 it displayed its leadership in the natural gas sector and tried to highlight how “natural gas provides a solution to…trade efficiency and noise emissions” (Sustainability Report). CNH Industrial then goes on to suggest to others in the industry that “[i]n order to minimize the noise impact of its plants, CNH Industrial encourages the adoption of procedures provided for by plant environmental management systems and by guidelines issued in previous years [from law-making entities] (such as the guideline for the design and purchase of new, low-noise machinery)” (Sustainability Report).
In its section under product development and advantages, the company discloses some quantitative data. This data is given when the company expresses its goal to use natural gas vehicles for company services. CNH Industrial states “NG-powered (natural gas) vehicles are ideal for distribution, short, medium, and long-haul logistics, and municipal services such as waste collection and transport. Moreover, they reduce noise pollution by 3dBA3 (decibels) compared to diesel engines” (Sustainability Report).
This example goes to show how CNH is a leader in transparency about steps to combat noise emissions. This example also shows how companies can be transparent, even with a lack of quantitative data. Because the CDSB framework allows both quantitative and qualitative data, it is ultimately up to the company to decide what to report. Perhaps many companies are taking the qualitative path and publishing narratives in their ESG reports regarding non-GHG emissions to not clutter their reports with information that they feel is beyond what stakeholders need to know. In general, stakeholders may only desire a narrative like shown above. Ultimately, as seen in the CNH example and others in industry, it seems that many stakeholders appreciate a narrative. Following in the steps of CNH Industrial and publishing a narrative for stakeholders is an effective reporting path for noise pollution and other non-GHG emissions.
Stellantis 2021 Corporate Social Responsibility Report
Stellantis is a leading global automaker and mobility provider that brands itself by offering clean, affordable, and safe transportation. It aims to achieve this goal with ambitious innovation in electrification, software strategies, and a unique combination of strategic partnerships.
The first mention of noise pollution is within the section Electrification Strategy. Stellantis reports that as part of its training to employees on electrification, the company discussed topics of “hybrid and electric car architectures to reduce noise, vibration, and harshness levels regarding battery cells and [battery] packs” (Sustainability Report).
On the topic of Stellantis’ manufacturing plants, it reported similarly to other companies in its sector stating that the company is in the process of “risk assessments [regarding] the danger of deafness and noise prevention in [manufacturing] plants” (Sustainability Report). To counteract these dangers, Stellantis is engaging in “open communications of the danger of excessive noise” with its employees and implementing risk reduction programs like medical surveillance, as necessary (Sustainability Report).
In a product section discussing hybrid and electric cars, the company goes through lengths to communicate its stance on background noise and quality: “[our] criteria encompass the aesthetic, aging of materials, tolerance of harsh treatment resulting from daily use, and functional aspects like background noises and loss of minor performances. Stellantis improves vehicle quality to reduce signs of aging and wear and tear, with the intention for the vehicle to look as close to new after years of customer usage as possible” (Sustainability Report). The company then proceeds to mention that combating noise is one of its core challenges in the design and engineering phase of vehicle production. In this section the company disclosed the following:
Design vehicles to reduce their impact:
- on the environment: CO2 emissions, local pollutants, the use of resources and recyclability;
- on society: road safety, noise pollution, and traffic congestion.
In its final messages towards noise pollution, it’s summarized how the emission of noise is one of the company’s core challenges under CSR ISSUE/CHALLENGE #17: Control of industrial discharges and nuisances. Stellantis states that it is trying to combat “noise or odor generated by industrial processes or accidental releases of chemicals with potential impact on other environmental media…[by] implementing processes to limit and reduce air emissions, including cleaner painting processes, the post-processing of residual emissions, noise and odor level monitoring and substitution of hazardous substances with non-hazardous ones where possible” (Sustainability Report). And lastly that “noise and odor caused by our operations may cause nuisances to our neighbors including residential areas located close to our facilities. We seek to address the potential risks by conducting impact studies and action plans potentially associated with our manufacturing facilities” (Sustainability Report).In total, we can see throughout the mentions in this report that Stellantis takes noise pollution as a serious, material matter in the industry and is trying to implement countermeasures. And while this report may also lack quantitative data, the in-depth qualitative analysis Stellantis gives is more than adequate to fulfill the CDSB guidance in providing to stakeholders the pertinent data that is need-to-know. Narratives like this one are shining examples of what other companies in similar industries should publish regarding non-GHG emissions transparency for stakeholders.
Conclusion
The current lack of structured reporting on the topics of noise pollution and non-GHG emissions is apparent. While greenhouse gasses are a hot-button topic, and increasingly being reported, non-GHG emissions like that of noise are being left behind in terms of the amount of reporting and disclosure. The importance of reporting these emissions is increasing as non-GHG emissions are also health risks and societal problems. Companies compliant with the CDSB show strong transparency in noise pollution and other similar emissions. The published narratives like that of CNH Industrial and Stellantis show that there is headway being made in the non-GHG emissions field. ESG reports like these demonstrate how this valuable information can be included in the company reporting and increase the transparency of complex company responsibilities.
References
https://www.congress.gov/bill/117th-congress/house-bill/4892/text?r=3&s=1#:~:text=Introduced%20in%20House%20(07%2F30%2F2021)&text=To%20reestablish%20the%20Office%20of,Agency%2C%20and%20for%20other%20purposes
https://www.law.cornell.edu/uscode/text/42/7641
https://www.ifrs.org/content/dam/ifrs/groups/cdsb/cdsb-framework-2022.pdf
https://www1.cnhindustrial.com/en-us/sustainability/corporate_sustainability_reports/reports/2021%20CNH%20Industrial%20Sustainability%20Report.pdf
https://www.stellantis.com/content/dam/stellantis-corporate/sustainability/csr-disclosure/stellantis/2021/Stellantis_2021_CSR_Report.pdf
