By Chip Duffie
In the words of the famous psychologist Karl Jung, “You are what you do, not what you say you’ll do.” So, what are you doing to manage environmental, health and safety (EHS) at your company?
Most company leaders generally recognize the need to do it right. But the costs seem endless, the regulations are complicated, the processes feel disruptive, and the value seems intangible. Motivation can, unfortunately, become centered around simply “staying out of trouble.”
Good News And Reality
Let’s start with some good news. EHS programs are making a difference. Worker deaths in America are down-on average, from about 38 worker deaths a day in 1970 to 15 a day in 2019. Worker injuries and illnesses are down-from 10.9 incidents per 100 workers in 1972 to 2.8 per 100 in 2019.
More good news. Multiple studies, including several sanctioned by the National Safety Council, have confirmed that every $1 invested in injury prevention and safety programs return between $2 to $6.
Of course, for most companies, EHS program success is fragile, and every company has unique risk factors that are constantly evolving. There is always the risk of injuries, penalties, increased insurance premiums, and even bad press that can drive costs into your business.
The reality for every business: Managing EHS programs is a constant challenge for business leaders. Not just to stay in compliance, but to manage risk and protect the employees, all while trying to demonstrate a return on investment for the program. The fact is that companies of all size struggle to balance regulatory concerns with maximizing productivity and revenue generation.
EHS Excellence Is Not Just For The Big Companies
Perhaps surprisingly to some, implementing a safety or environmental management system (a SMS or EMS) is not reserved just for big companies. For small to mid-size businesses without robust EHS support teams, trying to manage EHS programs can be intimidating and frustrating. While no one wants to operate out of compliance or put their employees at risk, many companies feel overwhelmed and do not believe they have the aptitude or resources to follow best practices.
At the core of this motivation is the idea that EHS programs are an “add-on” or something that must be layered on top of operations. This perception often leads to compliance and safety programs being considered a impediment to progress. However, the safest and most heavily regulated brands in the world use management systems to integrate EHS requirements into operations, setting programs up designed to actually increase productivity.
11 Key Factors For Success
I believe any size company can incorporate compliant practices into their daily operations. Here are 11 key factors to a successful implementation:
1. Leadership Engagement. The single most important factor to a successful SMS/EMS and long-term cultural improvement is the engagement and support of executive leadership. If it’s important to the boss, it will be important to the staff. It’s really that simple.
2. Get Documentation In Order. Archive old policies and ensure new policies are clearly communicated to all employees. Also, make sure the policy is customized to fit your business. A generic policy may check a box, but likely does not actually help your program, especially in an emergency. A systematic review of your program documentation will clarify roles, responsibilities and risks.
3. Set an Action Cadence. Get on a repeatable, sustainable schedule of inspections, training, meetings and safety huddles that your employees understand and will come to expect. You have to be disciplined and consistent, but it will rapidly become second nature to everyone.
4. Leadership Committee Meetings. A management system does not run itself. Executive involvement in meaningful, routine committee meetings is critical. A Management Committee sets goals, approves policies, solves problems, develops a communication plan and addresses escalated issues.
5. Identify Key Performance Metrics. The safest and most compliant brands track many key metrics related to their programs, and a company needs to set goals and targets for these metrics. Also, encourage your team to come up with additional site-specific metrics to be measured and tracked.
6. Employee Training. Make sure all employees know how do their job right. Of course, you have to meet OSHA and EPA minimum standards, but a management system does not settle for the minimum. Job specific training and apprenticeship programs are the best way to reduce injuries and ensure compliance.
7. Accountability and Recognition. A SMS or EMS is a team effort, and no one is above the requirements. There must be consequences for repeated failures and there should be a way to recognize outstanding contributions.
8. Employee Engagement. The operations staff know the actual risks of their job, so ask for their involvement and feedback and involve them in crafting solutions. A management system does not simply hand down high level policy, it is built from the ground up and gives the employees input in the process. It also allows them to take a positive messages home to their families every day.
9. Assess Risk by Job Type. A management system looks at every job and identifies the risk of noncompliance and the hazards facing employees. This is again more than checking a box, it is making sure every employee knows how to do the job right. A robust job type risk review will also give you confidence that you know how to onboard work-ready employees.
10. Leverage Leading and Lagging Indicators. Move beyond only relying on metrics that track the past, which are only looking in the rear-view mirror. Track leading metrics like training and behavior-based observations to ensure you can avoid problems before they happen.
11. Standardize Practices and PPE Across Multiple Sites. Many companies struggle with standardization, especially when it comes to job training and buying personal protective equipment (PPE) for multiple operations. Take the time and effort to get everyone on board with the management system and drive consistency across all your operations.
Top 10 Most Frequently Cited OSHA Standards Violated
The following were the top 10 most frequently cited standards violated by Federal OSHA in fiscal year 2020.
1. Fall protection in construction
2. Hazard communications
3. Respiratory protection
4. Scaffolding in construction
5. Ladders in construction
6. Control of hazardous energy
7. Powered industrial trucks
8. Fall protection training requirements
9. Eye and face protection
10. Machinery and machine guarding
To search the top violations of an industry with a specific NAICS code, see https://www.osha.gov/pls/imis/citedstandard.html
To search and view the industry profile for violations of any specific OSHA standard, see https://www.osha.gov/pls/imis/industryprofile.html
A management system is not a short-term play, it is an investment in your brand and your people that will pay dividends for years to come and define the way you do business.
Chip Duffie is a senior Lighthouse consultant who specializes in environmental, health and safety (EHS). An environmental lawyer by trade, Chip spent his early career as assistant general counsel and chief compliance officer for Safety-Kleen, and then as SVP, compliance and sustainability for Clean Harbors. His primary job as CCO was leading an in-house team of EHS professionals responsible for the safety and compliance of North American operations. A frequent speaker on EHS, legal and risk management issues, Chip has a passion for delivering simple, affordable technology to help businesses maximize operations while staying in balance with the environment and protecting their employees. To contact Chip, call him at 469-999-2500 or email him at email@example.com.
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