Ensure your EHS Program Authorizes Action
Written By Chip Duffie
Edited by Jo Gardner
“You are what you do, not what you say you’ll do”~ Karl Gustov Jung
NORA members constantly strive to balance environmental, health and safety (EHS) compliance with maximized productivity and revenue generation. Companies of all sizes struggle with how to operate within everchanging regulations while staying in business. To implement best EHS practices, your program must authorize action. Yet, many companies fail to integrate consistent EHS practices into their operations. As a result, they often find themselves scrambling to comply with an agency request, customer RFP or even a plaintiff’s demand. One area that companies struggle with is having organized program documentation that empowers employees and departments to take action.
At the core of any EHS program are the policies, procedures, training and inspection records, and company guidance that give a program its purpose and direction. As Dr. Jung’s quote highlights, you can only be as good as your actions. Having a policy alone is not enough, you must have a workforce and management team empowered to take action. It is a simple, but often overlooked, element of a heathy EHS program. Even if your company can not implement a full- blown ISO or EHS management system, making sure your employees know what actions to take and when to take them is a simple best practice that can be integrated into your policies and procedures. While that sounds easy in principle, too many companies have adequate documentation and principles, but fail to put those principles in action. In many cases, an injury or spill puts companies on the defensive and in reactive mode because they have simply failed to authorize action. This hurts everything from productivity to morale.
Here are three common reasons we see that cause Companies to endure this (avoidable) fire drill:
1. The EHS Program is Invisible
It is critical to have Directives that are clearly written and are available to all employees. This is particularly true in the event of an accident or release to the environment. If you downloaded your “Safety Program” from the internet, added your logo and shoved it into a drawer, then you are operating at risk. You need to take the time to ensure your program is customized to help you drive your business. It needs to specifically identify actions people can take. Additionally, the program needs to be available to all employees. You can use an old-school binder. You can use paper forms. But both of those manual methods are inefficient and prone to issues outdated versions suffer. A best practice is to make your program readily available through a mobile software tool or a company intranet site. No matter how you do it, until every employee knows where to seek guidance, your program is likely invisible.
2. Nobody Owns the EHS Program
Documentation is often generated and maintained by different people or departments that sometimes fail to communicate. This failure is commonly highlighted when there is a vehicle accident. As soon as an accident occurs, everything from driver drug testing to DOT training records come under scrutiny. In many companies, these records are spread out between departments like Human Resources, Operations and EHS. Someone must pull all the records and all too often there are gaps where one department thought the other was handling something, particularly when the accident involves a long tenured employee whose employee files are huge. Finding these gaps proactively can be done by putting an employee or department on point for collecting such information. A best practice is to undergo a mock discovery process with your insurance carrier – before you get sued.
3. EHS Dept. Owns Safety and Compliance – One Time Creation
Too many times companies treat their safety program as a “one and done.” That is, they spend considerable effort getting it up-to-speed. This is often a result of customer or agency demands. Once the program is rolling, EHS department claims victory, leaving the “program” to age on a shelf. EHS policies are dynamic documents. They must be changed as your operation changes. More than document stacks, the policies must mandate actions (ex. inspections, safety committee meetings etc.) that operations must undertake. Though your EHS and safety personnel support safety and compliance, operations must shoulder the responsibility to run the business safely. Knowing your program documentation must evolve as your businesses changes, you need a routine review of your program documentation. This not only updates your program, but almost always helps clarify roles, responsibilities and risks.
Companies with an organized, well-communicated EHS program significantly reduce their risk and avoid the inefficiencies of filling an urgent document request. When companies set an action cadence and establish expectations that their operations owns their safety and compliance, they are on the leading edge of EHS program implementation. These companies are implementing best EHS practices. In doing so, regardless of the size, these companies can get organized and use their program to drive value directly to the bottom line.
EHS Momentum specialized in assisting companies of all sizes organize and implement their own EHS best practices through an action-based, mobile EHS program. Contact us to learn more.