How does your EHS system compare to the best?
1. Standards-based — they are grounded solely on the U. S. Code of Federal Regulations and other official statutory requirements.
2. Multi-programmed and “quality”-driven — they are built on the Plan-Do-Check-Act (or, PDCA) cycle for “Continuous Improvement” (also known as the “Quality” model), and, with this approach, multiple EHS programs are managed, including planning, training, inspection, and review.
3. Technologically-advanced — they are powered with relational database management technology (RDMT), or equivalent technology, integrating compliance management data within and between each program, eliminating redundant data and work efforts.
Let’s explore these three essential components to see how well your company’s EHS systems compare to the best.
Question #1: Are your EHS management systems (and programs) grounded solely on the U. S. Code of Federal Regulations and official statutory sources? Are they standards-based? Will they hold up in a court of law?
Simply, your systems must be based on the law, and they must be able to hold up in a court of law. Unfortunately, and, often unknowingly, many EHS management systems are derived from so-called “sources” that everyone assumes were developed from official regulatory guidance.” The difference is important because assumptions and derivations may or may not hold up in a court of law.
Should a worksite accident or incident occur — an injury to a worker and/or an environmental incident – the first questions lawyers, prosecutors, judges, federal inspectors, and others are likely to ask, are: “May we examine your EHS program recordkeeping and documentation?” Or, they may ask, “May we see the ‘tangible evidences’ of your EHS planning, training, self-inspection, review, and other programs?”
OSHA inspectors are going to ask similar questions at the “opening conference” of an onsite inspection. (OSHA, FOM, 2011.)
When they ask for these documents, OSHA inspectors are checking to see if your company is employing standards-based programs, and that your company is effectively working those programs. They’re asking, “How does this company’s EHS programs compare with the law? Are they outdated? Are they incorrect or inaccurate?” Or, as required, “Are they based on current statutory law, and do they employ and/or direct users to valid statutory guidance?”
You might as well ask these types of questions of your company’s EHS management systems right away, as they will likely be the first questions inspectors, lawyers and others will be asking.
Question #2: Do your EHS management systems consist of multiple programs, including planning, training, inspecting, and review? Are those programs built on the Plan-Do-Check-Act (or, PDCA) cycle for “Continuous Improvement,” or, “Quality” model?
According to the OSHA, the major elements of an effective occupational safety and health management system are: 1) Management Commitment and Employee Involvement; 2) Safety and Health Training; 3) Worksite Analysis; and 4) Hazard Prevention and Control. (OSHA, 2005)
The pattern seen in OSHA’s “major elements” are similar to (and, most likely, based on) the Plan-Do-Check-Act (or, PDCA) cycle for “Continuous Improvement,” or “Quality” model. PDCA is “an iterative four-step management method used in business for the control and continuous improvement of processes and products.” (Rother, 2010) These steps are: “1) Plan: determine what needs to be done, when, how, and by whom. 2) Do: carry out the plan, on a small-scale first. 3) Check: analyze the results of carrying out the plan. 4) Act: take appropriate steps to close the gap between planned and actual results.” (WebFinance, 2012)
The best EHS management systems translate these “major elements” and “continuous improvement processes” into programs, typically: 1) planning; 2) training; 3) inspecting; and 4) reviewing programs, respectively. These programs help companies: 1) identify and prioritize EHS requirements applicable to specific worksites and associated operations (i.e., “Plan”); 2) implement plans and train company workers with EHS requirements (i.e., “Do”); 3) identify EHS hazards and investigate incidents (i.e., “Check”); and 4) eliminate EHS hazards and manage corrective actions (i.e., “Act”).
Question #3: Are your EHS management systems powered with Relational Database Management Technology (RDMT), or equivalent technology? Do they share EHS compliance management data relationally within and between multiple programs?
There’s one more component that makes a management system a system in every sense of the word: relational database management technology (RDMT), or equivalent technology, such as Microsoft’s® SQL Server or Access for databases. Typically, systems that employ these types of technologies are sophisticated, robust, yet easy-to-use. More importantly, these types of technologies integrate data and programs, and, consequently, make everything about EHS compliance management within an EHS management system so effective and efficient.
RDMT allows management systems to store large amounts of compliance management data – data external to the organization (e.g., federal regulations, voluntary guidelines from the OSHA and the EPA, etc.) and data generated from within the organization (e.g., program plans and reviews; self-inspection findings and corrective actions; training schedules and lesson plans; etc.).
Most EHS management systems are not powered with RDMT; the majority of these “systems” employ flat file and word processing technologies, such as Microsoft’s® Excel and Word. These types of systems are inadequate for querying large amounts of data, in the ways often required by EHS managers. What’s more, data is not shared relationally within or between programs.
This is not to say that these types of systems should be abandoned, nor diminished in value; they have their rightful places in the EHS manager’s “toolbox.” But the difference between flat file management systems and RDMT-based systems is like the difference between a “hammer and nails” and a “pneumatic nail gun.”
A system is an established arrangement of components that work together to attain a certain objective, in this case to prevent injuries and illnesses in the workplace. Within a system, all parts are interconnected and affect each other. All elements of a safety and health system are interrelated. All pieces are related to all other pieces. A flaw in one piece will probably impact all the other pieces, and therefore the system as a whole. (OSHA, n.d.)
There’s one more significant benefit of management systems built on the three components described in this article: they make great “stepping stones” to achieving various federal recognitions and honors, such as the coveted OSHA’s Voluntary Protection Program (VPP) “Star” and “Merit” recognitions, and the EPA’s “Environmental Merit” award.