How to get operating locations to embrace a new EHS program that the corporate office developed is a challenge for many of you. Traditionally, a top-down knowledge approach is used. The result? Corporations spend millions of dollars developing EHS programs that sit on the shelf because they are designed from a detached distance.

In this article I want to discuss using a bottom-up approach that will result in time-saving, practical, field-focused, and easy to implement corporate EHS programs - programs that are effective in controlling the events they target. To achieve these results, you must leverage the strengths of all your employees, particularly the individual employee/operator.


When a corporate office takes the time to develop a detailed, practical, field-tested EHS program, the operating location's job is much simpler. Generally, there is a lot of commonality within operating locations. The operating location can use the corporate template and make the program site-specific with only minimal work. Operating locations can then spend their time focusing on implementation and ensuring compliance with the program - instead of wasting time in the office developing and creating their own program.

This bottom-up EHS program development process is very efficient and results in tremendous labor savings. Granted, it takes man-hours for corporate personnel, working with several field employees, to write an equipment specific procedure, for example. But if the team does it right the first time, it saves each operating location from developing the same procedure 500 more times.

Use this bottom-up process to standardize your procedures, and to eliminate different interpretations of regulations within your company. An inspector visiting similar operating locations will see consistent application of the OSHA regulation throughout your company.

This consistency and uniformity allow your purchasing people to leverage vendors when buying equipment, such as energy control devices. If lockout-tagout programs are developed separately at each operating location, different pieces of energy control equipment are specified. This of course dilutes the buying influence of your entire corporation.

Customizing lockout-tagout

At a Fortune 250 waste services company with more than 500 operating locations, the corporate EHS office used this bottom-up approach to develop numerous programs, including one to comply with OSHA standard 1910.147 - Control of Hazardous Energy. The key question that needs to be asked: "Ultimately what needs to be done at the lowest level within the organization?" For this particular program, equipment-specific energy control procedures, training, periodic inspections, and a written program were needed that focused on mechanics at the operating locations.

So several weeks were spent at operating locations. Experienced safety professional(s) listened and engaged employees/operators in the program development process. Developing this energy control program required sitting down with mechanics at the operating location, not with managers or safety professionals. Professionals reviewed the mechanics' jobs in detail; watched them work; identified all the sources of hazardous energy; asked questions; and asked which energy control method would be the easiest, cheapest, and simplest to implement and still be in compliance with OSHA requirements.

Each written energy control procedure was developed by mechanics working with the corporate safety team. Procedures were tested at other operating locations to get input from other maintenance personnel. When locations would find safer, simpler methods to perform the energy control process, those methods were incorporated into the procedures. This is an efficient method to share best practices. Procedures are modified once at the corporate level and then dispatched to operating locations.

The result? This waste services company now possessed written energy control procedures that were practical, simple, and effective. These written procedures served as the foundation for the corporate-wide energy control program. Some procedures required tweaking at a few of the operating locations, but since the template was available, customizing the program for each operating location was easy.

In the end, the company had a program that was easy to implement, even though it contained hundreds of equipment-specific energy control procedures. To become site-specific, the written program simply needed the operating location's name added. A form for conducting periodic inspections and a training program was included.

Training focused on how to influence mechanics' behaviors. Instead of using a generic training program on lockout/tagout, an internal program was created using site mechanics. They explained what they do on a day-to-day basis, in their own words. This made training readily accepted in the field and easy to understand because it was presented in the mechanics' own language. And training showed the LOTO procedure being performed on equipment similar to what they maintain at their own operating location.