Health, Safety and Environment Management System

Introduction

Many people are interested in an organization's approach towards environment, health and safety (EHS) management including customers, clients, and suppliers; the community; shareholders; contractors; insurers; and regulatory agencies. More and more organizations attach the same importance to high standards in EHS management as they do to other key aspects of their activities. High standards demand a structured approach to the identification of hazards and the evaluation and control of work-related risks.

A comprehensive legal framework already exists for EHS management. This framework requires organizations to manage their activities in order to anticipate and prevent circumstances that might result in occupational injury, ill health, or adverse environmental impact. This chapter seeks to improve the EHS performance of organizations by providing guidance on EHS to integrate EHS management with other aspects of the organization.

Many features of effective EHS management are identical to management practices advocated by proponents of quality assurance and business excellence. The guidelines presented here are based on general principles of good management and are designed to integrate EHS management within an overall management system by establishing an EHS management system, EHS risks are controlled in a systematic proactive manner.

Within many organizations, some elements of EHS management are already in place, such as policy and risk assessment records, but other aspects need to be developed. It is important that all the elements described here are incorporated into the EHS management system. The manner and extent, to which individual elements are applied, however, depend on factors such as the size of the organization, the nature of its activities, the hazards, and the conditions in which it operates. An initial status review should be carried out in all organizations that do not have an established EHS management system. This initial status review will provide information on the scope, adequacy, and implementation of the current management system. Where no formal management system exists, or if the organization is newly established, the initial status review should indicate where the organization stands with respect to managing risks.

Environmental Health and Safety Policy

Top management should set in place procedures to define, document, and endorse a formal EHS policy for an organization. The policy should clearly outline the roles and expectations for the organization, faculty, EHS personnel, and individual employees. It should be developed in communication with employees to ensure that all major concerns are adequately addressed.

The EHS policy should state intent to

• Prevent or mitigate both human and economic losses arising from accidents, adverse occupational exposures, and environmental events;
• Build EHS considerations into all phases of the operations
• Achieve and maintain compliance with laws and regulations; and
• Continually improve EHS performance.

The EHS policy and policy statement should be reviewed, revalidated, and where necessary, revised by top management as often as necessary. It should be communicated and made readily accessible to all employees and made available to relevant interested parties, as appropriate.

Management Commitment

Management commitment to EHS performance is widely recognized as one of the elements most critical to EHS program success and to the development of a strong culture of safety within an organization. Therefore, the management system document establishes management commitment with a formal statement of intent, which defines examples of how performance goals are supported. Examples of how this commitment is supported include the following:

• Establish methods to use energy more efficiently, reduce waste, and prevent accidents.
• Comply with laws, regulations, and organizational requirements applicable to their operations.
• Improve EHS performance continually.
• Conduct periodic assessments to verify and validate EHS performance.

Planning

Planning is an integral part of all elements of the management system and to be effective involves the design and development of suitable processes and organizational structure to manage EHS aspects and their associated risk control systems proportionately to the needs, hazards, and risks of the organization. Planning is equally important to deal with health risks that might only become apparent after a long latency period. It also establishes objectives that define the criteria for judging success or failure of the management system. Objectives are identified on the basis of either the results of the initial status review, subsequent periodic reviews, or other available data.

Various sources of information are used to identify applicable EHS aspects and to assess the risk associated with each. Examples include, but are not limited to, information obtained from the following:

• Hazard/exposure assessment,
• Risk assessment,
• Inspections,
• Permits,
• Event investigations (injury and illness investigations, environmental incident investigations, root-cause analysis, trend analysis),
• Internal audits and/or external agency audits,
• Fire and building codes,
• Employee feedback concerning unsafe work conditions or situations,
• Emerging issues,
• Corporate/institution goals, and
• Emergency management

Once applicable EHS aspects are identified, a risk-based evaluation is performed to determine the potential impact and adequacy of existing control measures. If additional controls or corrective actions are needed to reduce risks to acceptable levels, they are integrated into business planning. Categorizing each item in this manner allows gaps that are identified to be prioritized and incorporated, based on level of importance and available resources.

Care should be taken when developing and disseminating new controls and corrective actions. If requirements are perceived by laboratory personnel as unnecessarily onerous, there is potential for lower compliance within the organization and a loss of credibility on the part of EHS personnel. While understanding that some individuals will never be convinced of the need for new controls, it is important to provide clear, supported justifications for changes to existing protocols to encourage adoption of the new policies and procedures.

Implementation

The design of management arrangements should reflect the organization's business needs and the nature of their risks. However, there should be appropriate activity across all elements of the model (policy; planning; implementation; performance measurement, audits, and change management; and management review).

Specifically the organization should make arrangements to cover the following key areas:

• Overall plans and objectives, including employees and resources, for the organization to implement its policy;
• Operational plans to implement arrangements to control the risks identified;
• Contingency plans for foreseeable emergencies and to mitigate their effects (e.g., prevention, preparedness, and response procedures);
• Plans covering the management of change of either a permanent or a temporary nature (e.g., associated with new processes or plant working procedures, production fluctuations, legal requirements, and organizational and staffing changes);
• Plans covering interactions with other interested parties (e.g., control, selection, and management of contractors; liaison with emergency services; visitor control);
• Performance measures, audits, and status reviews;
• Corrective action implementation;
• Plans for assisting recovery and return to work of any staff member who is injured or becomes ill through work activities;
• Communication networks to management, employees, and the public;
• Clear performance and measurement criteria defining what is to be done, who is responsible, when it is to be done, and the desired outcome;
• Education and training requirements associated with EHS;
• Document control system; and
• Contractors should have written safety plans and qualified staff whose qualifications are thoroughly reviewed before a contract is awarded. All contractor personnel should be required to comply with the sponsoring organization's safety policies and plans.

Though it is the responsibility of each individual to ensure that work is performed in a prudent and safe manner, achieving a safe environment is a cooperative endeavor between management, EHS personnel, and employee. Regulations, policies, and plans will never cover every contingency, and it is important for these different groups to communicate with each other to ensure that new situations can be handled appropriately. One way to ensure that the needs of all groups are being met is by creating safety committees consisting of representatives from each part of an organization. In this forum, safety concerns can be raised, information can be distributed to affected parties, and a rough sense of the efficacy of policies and programs can be gained.

Performance Measurement

The primary purpose of measuring EHS performance is to judge the implementation and effectiveness of the processes established for controlling risk. Performance measurement provides information on the progress and current status of the arrangements (strategies, processes, and activities) used by an organization to control risks to EHS. Measurement information includes data to judge the management system by

• Gathering information on how the system operates in practice,
• Identifying areas where corrective action is necessary, and
• Providing a basis for continual improvement

All of the components of the EHS management system should be adequately inspected, evaluated, maintained, and monitored to ensure continued effective operation. Risk assessment and risk control should be reviewed in the light of modifications or technological developments. Results of evaluation activities are used as part of the planning process and management review, to improve performance and correct deficiencies over time.

Periodic audits that enable a deeper and more critical appraisal of all of the elements of the EHS management system should be scheduled and should reflect the nature of the organization's hazards and risks. To maximize benefits, competent persons independent of the area or activity should conduct the audits. The use of external, impartial auditors should be considered to assist in evaluation of the EHS management system. When performing these reviews, it is important that the organization have a plan for following up on the results of the audit to ensure that problems are addressed and that recognition is given where it is deserved.

The concept of change management in the work environment varies evidently from methods typically prescribed, for example, in manufacturing operations. By its very nature, the business of conducting experiments is constantly changing. Therefore, it is a part of everyday activities to evaluate modifications and/or technological developments in experimental and scale-up processes. As such, a number of standard practices are used to identify appropriate handling practices, containment methods, and required procedures for conducting work in a safe manner.

Management Review

Top management should review the organization's EHS management system at regular intervals to ensure its continuing suitability, adequacy, and effectiveness. This review includes assessing opportunities for improvement and the need for changes in the management system, including the EHS policy and objectives. The results of the management review should be documented.

Among other information, a management review should include the following:

• Results of EHS management system audits,
• Results from any external audits,
• Communications from interested parties,
• Extent to which objectives have been met,
• Status of corrective and preventive actions,
• Follow-up actions from previous management reviews, and
• Recommendations for improvement based on changing circumstances.

The outputs from management review should include any decisions and actions related to possible change to EHS policy, objectives, and other elements of the management system, consistent with the commitment to continual improvement.

The management system review ensures a regular process that evaluates the EHS management system in order to identify deficiencies and modify them. Systemic gaps, evidence that targets are not being met, or compliance issues that are discovered during compliance or risk assessments indicate a possible need for revision to the management system or its implementation.