How to be an EHS 'General Practitioner'
With technology progressing so fast in some areas that textbooks are out of date before they are printed, the necessity of continual education beyond a college degree is understood by those individuals who want to survive and advance in the industry. Technical reading, attendance at conferences and seminars, review of equipment demonstrated by manufacturers and vendors, and continued contact with representatives of regulatory agencies are all key methods employed by dedicated managers to stay on top of the situation.
The push for specializationIn an effort to identify and disseminate important information, groups of professionals that face common problems have banded together to share information and resolve problems. The National Safety Council, American Board of Industrial Hygiene, American Society of Safety Engineers, American Conference of Governmental Industrial Hygienists, and other such groups have tried to provide a forum to individuals responsible for safety and health issues. However, as the amount of information and responsibility grew, specialization became more important.
Regulations are packed with requirements that preclude individuals from conducting job tasks without specific training and certification.
The trend toward specialization was further enhanced as the social fabric of American society changed from discussion and compromise to litigation. With increased liability it became more important for individuals with decision-making authority for safety, health and environmental concerns to be able to support their professional opinions. While this support was generally considered to be derived from specific college degrees and work experience, additional proof of expertise in a particular area was frequently demanded.
To fill the gap, many organizations that originally began as voluntary associations started to develop professional standards of practice. As these industry standards grew more complex, mastery of them took more time and effort. This in turn led the individuals who had met the challenge of assimilating important information in their field to separate themselves from others who hadn't invested similar effort into the profession.
As a result, testing and certification programs grew in importance. Certified Industrial Hygienist, Certified Safety Professional, Certified Environmental Trainer, Hazardous Materials Manager, and a host of other titles have formed a veritable alphabet of initials after the name of safety, health and environmental professionals.
This trend toward specialization has been embraced fully by the regulatory agencies. OSHA and EPA regulations are packed with requirements that preclude individuals from conducting various job tasks without specific training and certification. For example, asbestos samples cannot be collected without certification as an asbestos inspector. Chemical spills cannot be approached without certification as a first responder, while other laws restrict individuals from assessing lead paint hazards without verification of proper training.
Counter trendWhile the information explosion, the risk of liability, and regulatory mandates are pushing a greater number of individual certifications, a counter-trend is occurring in the world. The drive by business to become more efficient has led to company downsizing with a number of far-reaching effects.
One of the most noticeable impacts is the consolidation of a variety of responsibilities in a single department. While many organizations had separate departments for safety, industrial hygiene, and environmental concerns in the past, today's world has found most of these functions consolidated into a single department. Indeed, even additional responsibilities such as permitting, waste disposal, security, fire protection, medical, and even human resources have been added to some environmental safety and health departments.
While this consolidation is often driven by downsizing and cost considerations, it is also an acknowledgement that today's complex situations and problems cross traditional boundaries. Is ergonomics a safety or an industrial hygiene issue? Is violence in the workplace an issue only to be dealt with by security, or do human resources and the safety department have a role to play?
The list of such questions of "jurisdiction" goes on and on. Even the regulatory agencies which encourage the specialization trend contribute to the appropriateness of consolidation by the promulgation of regulations covering the same topic by different agencies. The lack of substantial coordination between EPA, OSHA, and HUD regarding lead control requirements reflects the differing viewpoints of each agency and helps to blur jurisdictional lines for individuals who must interpret and follow their mandates.
What past experience teaches usThe history of asbestos is another example where these two trends-increasing specialization and a broad approach-have collided. Emerging science in the 1960s and 1970s alerted the public to the dangers of this carcinogenic material. Public pressure had a major impact on rulemaking covering asbestos. Regulations were written to force specialization in an attempt to control known abuses.
With a regulatory spur, the specialization of asbestos knowledge led to the requirement for specific certifications. A power struggle of sorts ensued as voluntary organizations, industry groups, and the government all jockeyed for position in the effort to determine whether specific asbestos credentials should be self-certified by business (i.e. similar to the American Board of Industrial Hygiene authorizing certification for industrial hygienists), or accredited by federal or state regulatory agencies.
In the end, the EPA set industry training standards through the Asbestos Hazard Emergency Response Act (AHERA) regulations. The federal government then pushed the responsibility for implementing this training to the individual states.
Certification confusionA number of problems have resulted from this situation. The lack of reciprocity between states for individuals who have received federally-approved training adds substantial unnecessary cost to asbestos control activities. More importantly, the ability to approach problems in a comprehensive fashion is compromised because generalists with significant experience in a wide range of safety, industrial hygiene and environmental matters must be replaced or supplemented with multiple specialists who hold the appropriate "credentials."
Requirements for redundant specialization and certification were recently pushed to new heights with OSHA's revision of the asbestos standard. Specific sections in that standard now require that a Certified Industrial Hygienist or Professional Engineer who also has training and certification as an Asbestos Project Designer are the only individuals qualified to develop and propose alternate abatement activities to those that are specified in the standard. This provision, in effect, narrows the field of "qualified" individuals substantially.
Lessons to be learnedSo what are safety and health professionals to do when conflicting trends impact their ability to do their work efficiently? Unfortunately, there is no simple answer, but awareness is the first step toward dealing effectively with the situation.
Since problems are not getting any less complicated, it is clear that safety and health professionals will have to put more effort into team building. This team can be assembled from individuals on the staff, if the organization is large enough. Efforts should be made to identify, hire, retain, and train individuals so that a variety of skills and certifications are present among the members of the safety/health/environmental department.
For individuals in smaller organizations, the team building may have to occur through professional colleagues, consultants, and contractors. Finding individuals whose resources you can tap for a reasonable fee is important before a crisis in one of these areas erupts, forcing you to take "whatever is available." An effort should be made to identify consultants and contractors who share your organization's values and approach.
Another lesson that these conflicting trends teach us is that learning is a life-long process. By being organized, professionals can continue to add to their knowledge base in such a fashion that necessary certifications are accumulated. Professional development seminars and certification training programs are often offered at the beginning or conclusion of major conferences or trade shows.
At a minimum, environmental, health and safety professionals must watch the regulatory process in areas where they have even tangential responsibilities. They must ensure that they do not conduct specific activities where requirements for certified individuals have been newly implemented at the federal or state level.
Keeping up with the trends
A third basic lesson that should be accepted is that in the foreseeable future multiple certifications are going to be required. As such, professionals need to watch the trends and offer greater input into the rulemaking process. By getting involved in the certification process early, it may be possible to have your current training and experience "grandfathered" into various programs.
Identify, hire, retain, and train individuals so a variety of skills and certifications are present in the department.
Finally, it is important for all of us in the environmental, safety, or industrial hygiene professions to remember the importance of a broad approach. In some respects, the trends in our profession are similar to those in the medical profession, where they have found that too much specialization has led to a dearth of general practitioners.
As the problems become larger and more complex, many professionals with safety, health, or environmental responsibilities will have to begin acting like the organization's "general practitioner" for a whole range of problems. They will have to coordinate the "treatment" by qualified individuals with appropriate credentials in order to meet the restrictions imposed by regulation and liability.
While such an approach may take a rethinking on the part of many individuals now practicing, the management skills garnered by this process can then be applied to other situations.