ECP - EMPLOYEE CONCERNS
PROGRAM
The Employee Concerns Program
("ECP") is designed to increase internal communication in an
organization while decreasing conflict. This is accomplished by creating an
alternate means within an organization for employees to express their problems,
“concerns” or even questions on a confidential basis without fear of
retaliation. In this way employees feel encouraged to communicate organization
problems so that these can be both identified and resolved. The process reduces whistleblowing
since employees can discuss their problems internally – there is no need for
external communication (adverse publicity, regulatory compliance and
litigation).
The Employee Concerns Program
evolved during the 1980's in nuclear power plants and is now being used
extensively throughout that industry. It is an integral part of what the
industry refers to as a Safety Conscious Work Environment ("SCWE"). A
key component of SCWE is to reduce the forces inhibiting the free flow of
communication between management and employees. By implementing the ECP, the
nuclear industry has created a culture of open "lines of
communication" where employees are willing to express their problems and
"concerns". This is essential in an industry, where by its very
nature, success is crucial.
The ECP in a traditional
nuclear power plant is an alternate means for voicing “concerns” but is
structured as an entity within the plant’s organizational structure. The
Director or Manager and staff are employees of the company. Notwithstanding, the
ECP function has a degree of independence in its activities and is reviewed by
the Nuclear Regulatory Commission. In the event of a difficult “concern” or
where even the appearance of impartiality is important, an ECP will generally
request the services of a skilled outside group or contractor to handle the
matter.
The ECP generally reports to
the CEO or a senior manager with a "dotted line" to the CEO. The ECP
Director manages his/her staff and the process. The number of personnel will
vary with the project. In a way, the program also functions as an additional and impartial
observer for Oversight (Nuclear Regulatory Commission).
The following diagram shows
the typical ECP process:
Mutually reinforcing common
characteristics of an ECP differentiate it from other programs. While some of
these may be found in other programs, they are not generally combined in this
manner. Key ECP elements are: (1) strong Oversight directive, (2) functional
independence, (3) enhanced Outreach techniques, (4) good investigator skills,
(5) factual determinations, (6) employee confidentiality, (7) prompt resolutions
and (8) feedback. These elements relate to the practical consideration of an
alternate organizational method working within another organization's structure
on a daily basis. If the management (and Nuclear Regulatory Commission’s)
directive is clear, the ECP should perform well in restoring and maintaining
organization effectiveness.
There are distinct advantages
for implementing an ECP:
Company
advantages:
- restores
organizational effectiveness
- assists
in resolving employee problems in-house
- re-establishes
channels of communication
- increases
qualitative & quantitative productivity
- enhances
regulatory compliance
- avoids
unwanted publicity/litigation
- reduces
employee fear of retaliation
- transfers
"lessons learned" for future avoidance
- maintains
a safe and healthy work culture
Oversight
advantages:
- innovative
monitoring technique
- increased
incident data
- information
with minimal Oversight
- advance
warning of potential wrongdoing
- affirmation
of regulatory vigilance
- greater
insight into Industry practice
- alerts
by "best informed" - the employees
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process
is initiated by a contact from an employee.
This
contact is made
on a
clear, predetermined level of confidentiality. The
employee is assisted in the contact interview by an ECP Counselor to frame a
"concern" or provide other helpful advice or direction. The ECP
Counselor conducts an investigation to establish whether the facts Substantiate/Unsubstantiate
the “concern”. A meeting is held with the employee to explain the results,
the reasons for the conclusions reached and to solicit any suggested
recommendations to management. A written Report is prepared, submitted to the
ECP Director and filed. Both the employee and management are informed of the
results. The parties are then better able to understand the reasons for the
“concern” and to decide on what will be appropriate Corrective Actions. In
the case of nuclear power plants, the Nuclear Regulatory Commission is promptly
informed of any potentially important concerns and is able to review specific
files and trends at any time.
