How to Re-Focus Your EH&S Strategy to Make It More Effective

Posted by Mark Roman on May 15, 2019

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As a facility manager, it seems you have an ever-growing list of responsibilities, but never enough resources to account for everything you must do.

Remember that environmental, health and safety (EH&S) is about much more than sustainability, which is the buzzword upper management and the outside world constantly emphasize. It seems to be all you hear as a facility manager, with the underlying message of “do more with less.”

But when it’s time to re-focus your environmental, health and safety strategy, there are several other key issues you need to fine-tune:

  • Regulations
  • Compliance
  • Safety
  • Permits
  • Training
  • Documentation
  • Plans and Procedures
  • Liability Management
  • Risk Reduction
  • History

Overlook these issues, and significant problems can occur with your day-to-day operations, the business’s reputation (not to mention yours), relationships with clients, relationships with regulators (with associated regulatory action and penalties), and the bottom line, which means even the business’s very survival is at stake.

And, of course, your job is on the line when anything negative happens, because the buck always stops with the facility manager.

All this means that you have to be proactive when dealing with EH&S issues specific to your facility now. And that probably means overhauling your current strategy to be more effective. It’s well worth it because it makes your job easier and less stressful with clear policies in place. You can be more efficient and effective.

You might say you already have a strong EH&S strategy in place… you’ve used it for years.

But what I see with most of these policies is that they are usually focused on compliance with local, state, and federal regulations. That is important. But simple compliance with monitoring, training, documentation, and other regulatory requirements is not enough. Your property can still have significant EH&S issues that can take time, money, and effort to correct.

Your focus must be on three elements…

1. Your current situation – what’s happening here and now.

2. What happened in the past – so you can learn from mistakes.

3. Look to your future by identifying potential exposures and managing the associated liabilities.

The foundation of all of this is the Core Four:

  • Communications
  • Facility Knowledge
  • Property History
  • Documentation

You cannot address EH&S issues without a thorough understanding of these concepts. So please read this article to get up to speed.

Once you have the Core Four in place, you are ready to use them to:

  • Communicate with team members at all levels of your organization.
  • Fully understand what your facility does and how it does it, as well as your property’s history – which is key in spotting potential problems.
  • Document everything that happens as well as reaching into the past to collect as much historical information as you can.

At that point, you identify and address common but often overlooked EH&S issues in three steps.

1. Define your approach to identifying EH&S issues.

Overall, you want your program to be proactive, not reactive. You should promote elimination of EH&S issues rather simply trying to control them to some level. For example, wouldn’t you want a strong fire prevention program rather than require a strong fire-fighting program?

2. Identify the issues at your facility and determine how your organization will address them.

A great place to start in identifying overlooked issues is to look to the regulations that pertain to your facility. There are so many regulations on the books… and they can be confusing. It can be hard to know which apply to your operations.

But there is help from consultants, industry associations, sister facilities, online (from an official, current source), regulator websites, guidance documents from regulators, and more. Once you know the regulations that apply… find out what permits you need, if any. And, review your current permits – they may no longer be valid.

Another common problem area with regulations: lack of required training (or proper documentation of that training) for your team.

One last thing here: don’t overlook the obvious. We call them Invisible Environmental Gorillas, which are exposures and liabilities at your facility that you can’t see because of “familiarity blindness” – your guard is down and your level of observation is muted because you are in an environment you’re in every day. The thing is that outsiders can usually see these issues right away – so get another set of eyes on your facility. And keep in mind that many of the most serious gorillas are hiding in chemical/liquid, storage, and usage areas.

For a free copy of our book, Overlooked: Hunting the Invisible Environmental Gorilla, click here. It’s a great resource to aide you in finding, and fixing, overlooked environmental risks before there is trouble!

3. Learn to better manage these issues than you have in the past.

Once you’ve started identifying and addressing EH&S issues more effectively… keep the ball rolling.

You want to set goals to strive to make your EH&S program better and make sure your whole team knows about them. And once you achieve goals… set new ones. That will promote an environment of continuous improvement and an attitude of “we can always do better.” And to make sure those environmental gorillas you’ve found don’t disappear again, make sure you address them with routine preventative maintenance.

This will ensure that your program will grow stronger over time instead of gradually falling by the wayside and growing weaker and less effective.

Remember that you must have policies to deal with normal problems that come naturally with day-to-day operations at your facility, as well as separate strategies in place to address non-compliant situations and emergencies.

Your Next Steps

Even if you have what you consider to be a robust EH&S strategy in place, in my opinion, facility managers should never have an attitude of “if it ain’t broke, don’t fix it.” Because trust me, your current program can definitely be improved upon. And for the peace of mind and reduction of the chance of expensive liabilities and/or regulatory action, it’s well worth it.

To help you as you re-focus your environmental, health and safety strategy, I already mentioned that the Core Four should be at the heart of your efforts. To make sure they’re top of mind, please refer to this free download:

The Core Four Requirements Checklist

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