Crisis management can create new risks — and crises. Just ask BP.

While testifying before the House Energy and Commerce Committee this week, BP was asked to disclose how much it has spent on advertising from April through July. The answer, a total of more than $93 million, irked U.S. Representative Kathy Castor (D-Fla.), who maintains that the company spent more on “polishing its corporate image” than it spent on directly helping Gulf Coast communities and business recover from the oil spill ($89.5 million in grants to Louisiana, Alabama, Mississippi, and Florida).

As they say (or at least once said) in public relations, “perception is reality.”

Rep. Castor’s points are a bit off, but her argument raises important risk management questions about crisis management, public relations, and marketing processes.

First, I don’t think BP’s advertising outlay qualifies as an “image polish”; I think it’s safe to say that their full-page newspaper ads (which also appear down here in neighboring Texas) veer more toward the “reputation survival mode” end of the communications spectrum. Second, BP reports that it has spent a total of about $6.1 billion on oil spill cleanup to date.

But these quibbles are beside a larger point for risk management professionals. When I read the account of this Congressional hearing exchange, it made me wonder how much risk management discipline exists within the corporate realm of external communications (i.e., a big bucket containing crisis management, disaster recovery, public relations, advertising, marketing, and sales processes).

Prior to the oil spill, BP received acclaim for branding itself as “Beyond Petroleum” – a marketing effort that suggested that the company was about much more than oil and profits (it was about people like you and me and our grandchildren, its sunny advertisements suggested, because BP was committed to finding more sustainable sources of energy). Of course, it turns out that neither BP nor, more important, you and I are beyond petroleum yet (or, probably, will bein the near future).

It also turns out that advertising, thanks to ever-increasing transparency within the business realm, may contain certain inherent risks that did not exist in the Mad Men era. Many stakeholders, including Rep. Castor, see advertising not for the message it conveys but for what it implies: spending money in an effort to sway public perception. The content of those ads does not matter in this context, only the decision to spend a bucketload on advertising and how that spending compares to other investments.

An ironic (or “painful,” or “interesting,” depending on your perspective) end note to this is that the advertising may be working: An Associated Press survey indicates that BP’s still-anemic public approval rate more than doubled from June to August.

So, is this massive advertising/crisis management investment effort worth it? I don’t think that we will know anytime soon. In the meantime, it makes sense to examine the degree of risk intelligently within existing public relations, marketing, and crisis management processes. ###