- OIL & GAS
EHS appealsHow do we appeal to someone that it is possible to achieve improvement to an environmental health and safety problem? The two most common ways are by following modern risk management processes (http://en.wikipedia.org/wiki/Risk_management) and employing theories for behavioral change (http://en.wikipedia.org/wiki/Transtheoretical_Model ).
Risk management usually applies to an organization. Behavioral change focuses more on the individual.
Table 1 above summarizes how the steps/stages for both of these concepts are connected by common elements.
1 - Identification/pre-contemplation
This critical step/stage requires the initiative of an EHS pro. The pro has to get beyond the “ignorance is bliss” position. Exploration and discovery are needed. EHS pros will have to step out of their comfort zone. Beyond the basic “what if” scenarios, a variety of risk identification processes â€” such as objective-based risk identification, common-risk checking and risk charting â€” may be employed. Facts as well as opinions come into play.
Here are a few thoughts that may spur your imagination at this step/stage: biomonitoring, genetic testing, medical surveillance, exposure registries, bioaccumulation, obesity, certification and pandemic.
2 - Assessment/contemplation
The basic formula to consider here is severity X probability = risk. How severe could the problem be? How often will the problem occur? Does the risk consider uncertainty? Risk must go beyond simple injury/illness and property loss considerations.
For example, could there be a risk to corporate or personal reputation? How about quality of life? Could addressing the risk be a competitive advantage for the employer? This step/stage should involve input from a team of various experts in business management, finance, human resources, public relations, ethics and law.
The team should give a “yes” or “no” response to the question of whether the problem should be addressed, or set a date for the problem to be revisited. The problem should not sit in limbo. Remember, during this step/stage we’re looking for what is possible to achieve, not just what is common practice. As an EHS pro, you should appeal by reason (e.g. logic and scientific method) and possibly, emotion, that best EHS practices should be employed. Hold the line on your views. Other people on the team could have strong opposing views with equally valid merits. The point of this step/stage is that a collective decision is reached on what to do.
3 - Plan/preparation
Beyond the basic hierarchy of controls (i.e. engineering, administrative and PPE), the EHS pro should understand risk management concepts such as risk retention (e.g. self insurance) and risk transfer (e.g. insurance or contract/outsource the risk to a third party). The step/stage #2 above emphasized the team; here the EHS pro may be mostly alone with their expertise, or a consultant’s expertise, to develop a plan to address the problem.
The plan should be reviewed and approved, however, by the team that participated in the assessment/contemplation.
4 - Implementation/action
Although the best practice may be singly viewed as a technique, method, activity, incentive or reward, it should be integrated into an EHS management system such as ANSI/AIHA Z10-2005 for best success. A key reason for this advice is that management systems usually spread controls and workload across the entire organization, and not just on the shoulders of the EHS pro.
5 - Review/maintenance
Best practices eventually become good management practices and the industry standard. Best practices are a pursuit of continual improvement. A metric and periodic audit should be developed for the best practice to ensure that it does not regress. For best success, the metric should be integrated into other management metrics such as a Balanced Scorecard for the organization/individual.
Putting it all togetherHow does this all work?
Consider the following scenario: In November 2007, NIOSH issued the “Current Intelligence Bulletin: Interim Guidance for the Medical Screening of Workers Potentially Exposed to Engineered Nanoparticles.” In a nutshell, the CIB suggests that it may be a best practice for employers to provide medical tests for asymptomatic workers exposed to engineered nanoparticles. Results from these medical tests may eventually be included in an exposure registry. NIOSH concedes that there is currently limited scientific evidence for this recommendation. NIOSH also warns that “nonspecific medical testing could have negative consequences including adverse effects of the tests such as radiation from chest radiographs, unnecessary anxiety from false positive screening test, and the cost of additional diagnostic evaluations.”
Assume your employer is now handling experimental quantities of engineered nanoparticles. How should you implement medical screening as a best practice? There is no OSHA requirement here, so appeals will have to work rather than force.
First, the EHS pro should identify and analyze the problem. If the pro doesn’t take this initiative, don’t expect that other people will bring the issue forward.
Next, a team is required to make an assessment of risk and determine what actions are needed. This is a management decision. If a decision is made to do something, the EHS pro uses his/her expertise to develop a plan of action.
Then, preferably, the organization and not just the EHS pro, approves and implements the plan.
Finally, the plan is measured to determine if it is working or needs improvement.
All of this is built into a management system and is not a stand-alone activity. When we follow the steps/stages outlined here, lasting change (i.e. improvement) occurs in the organization or the individual.
When we look at all that goes into developing a best practice, we realize that best practices are not universal. Depending upon unique circumstances, a best practice in one organization may not be a best practice in another organization. Similar organizations, however, may share best practices through a process of benchmarking.