Hundreds of organizations across the country ask themselves the same questions year after year. Are we adequately prepared in the case of an emergency? How can we get ahead of potential compliance issues? Could we be managing risk more effectively? The answers to these questions and more can be identified through the process of developing an effective Environmental Health and Safety (EHS) program—but where to begin? As with any new program, the logistical barriers to development can seem overwhelming, but once the legwork up front has been done, organizations find themselves in a much more comfortable position, with many of their perennial concerns fully addressed. If you’re considering developing a new program altogether, or simply revising an existing one, consider these points to create an EHS program that will be protective, compliant, effective, and a solid basis for a broader management system.
Accurately identify your needs. In order to generate a plan that will help manage your organization’s overall risk, your needs must be clearly defined. One of the first steps should be to identify EHS regulatory compliance obligations through an assessment that reviews your operations and physical facilities. Beyond basic regulatory requirements, you should also understand other potential risks associated with your operations so your EHS programs can address them. What are the potential environmental impacts of your operations? What are the most significant health or safety risks to workers? A thorough EHS risk assessment can provide a rational basis to allocate resources for the development and implementation of an effective EHS program.
Establish a documentation system. Documentation is critical for several reasons. For compliance purposes, you must be able to prove that requirements have been addressed; whether that means employee training records, completed inspection forms, or regulatory-driven reports. Your EHS program should identify what documentation is required and how and where it is maintained. Establishing a structure for an organized documentation system up front will save time later as records begin accumulating and will help ensure the continuity of existing programs despite personnel or operational changes. Depending on the amount of documentation you are required to maintain and who needs to access it, you may consider a database or an electronic document storage and management system.
Educate your employees. Even with the best written set of procedures and policies, your program won’t be effective unless your employees are aware of the procedures and policies and understand how they apply to them. When developing a training program, look beyond mandated training programs, and refer to your EHS risk assessment to be sure employees have the tools and information necessary to safely carry out their duties while minimizing risks. Don’t make the mistake of assuming that certain procedures or practices are common sense and don’t need to be emphasized. We all look at situations differently, and safety, in particular, requires constant vigilance. In addition to regular trainings, put up posters reminding employees of safety guidelines in areas where they are most likely to be used./p>
Evaluate effectiveness periodically. Developing and implementing an EHS program are just the first steps in the process. Even a well thought out, thoroughly vetted program should be evaluated to determine whether it is effective. Assess work areas to identify any gaps and work with personnel to correct them. Evaluate whether there are barriers due to lack of training or comprehension, inadequate equipment or tools, or procedures that require modification. Determine what metrics will help you evaluate EHS program effectiveness and track them. You may decide to monitor the number of incidents in a period, compliance with routine inspection requirements, training attendance, etc. This provides an opportunity to set measurable EHS goals and review your progress toward those goals regularly to ensure your program is having the effect you want it to. It can be encouraging to employees when goals are met and motivating when they are not.
Consider outsourcing. If you’ve read this blog post so far and thought, “This all sounds great, but where do we get the time and manpower to do it?” you’re not alone. Outsourcing some or all of the tasks involved in this process is an option for organizations of all sizes. For those without any EHS staff in-house, hiring a specialist to perform a compliance audit and work onsite periodically to collect compliance data and recommend and help implement corrective actions is an affordable way to make sure you’re covering all your bases without having to hire a full-time staff member. For those who have some EHS staff, but don’t have the capacity to develop a new program themselves, an EHS consultant can help on a one-time or regular basis to supplement your team and work with them to develop or enhance programs and manage responsibilities and tasks.
EHS programs can be created to fit every organization’s needs. Chances are there are plenty of other top-of-mind concerns you’re dealing with on a daily basis, and having a program in place that ensures regulatory compliance and employee safety and health can allow you to focus more directly on the operational needs of your business. If you start with these five essentials, you’ll be ahead of the game and on the right track for maintaining EHS compliance and successfully managing risk.
