The Main Elements of a Strong EH&S Program, Including What’s Usually Missing


The role of the facility manager has broadened over the years to encompass many responsibilities, including the facility’s physical structures and equipment, budgets and finances, training, compliance with laws and regulations (not to mention company policies, and employees).

It makes the job more challenging… and it’s always getting more difficult as environmental, health and safety (EH&S) issues become ever more important in our communities from the standpoint of politics, business, governmental policy, and the types of products produced.

It’s all part of today’s “green” society that wants to emphasize sustainability.

This is especially true for manufacturers.

One of the key elements to make for a smooth-running facility that maintains good client relations, regulator relations, and preserves your company’s reputation is an effective environmental, health and safety program.

Consider these four core requirements to be the foundation of the EH&S program you develop and put into practice:

Communications – You need to be well organized and efficient, be observant and knowledgeable, be able to increase awareness of problematic issues to all levels of your organization, and, perhaps most importantly, be approachable – be the guy or gal who people want to talk to and work with. Don’t punish those who come forward with issues or ostracize them as whistleblowers. You want an open line of communication.

Facility Knowledge – You have to know what your facility does and how you do it as far as the processes involved. In other words, raw materials to finished products to waste products. And you must know what permits, programs, policies, licenses and certifications you need (and may or may not have in place already). It’s not enough to know what’s been going on since you were hired. You have to reach back to understand…

Property History – This is probably the most important yet underused resource available to a facility manager and certainly makes the job easier (and cheaper for you) for any environmental consultant you hire on-site.

You must understand the history of what’s been done at your facility and keep that up to date on a routine basis. You might not think what happened in the past is important. But it is vital to take preventative measures for future potential issues with regard to facility planning, and the identification of risks and liabilities.

Sources for property history include old documents and plans, even aerial photos in your office lobby. You’ll see how the facility’s footprint and processes have changed over the years. Another great resource: long-time employees who’ve seen many changes over the years.

Documentation – You must have a central repository of all documents and records that are valuable and required (from a corporate and regulatory standpoint). This is where you should keep copies of all historical information, as well as any future work performed at your facility. Put it in a filing cabinet in your office. And make sure they are complete copies – not just summaries. There could be vital details in the fine print.

How to Fine-Tune Your EH&S Program to Be as Strong as Possible

When we visit facilities, we usually find that most do have a well-developed EH&S program. But it’s usually focused on the compliance with local, state, and federal regulations.

But compliance is not enough. You must look to the present, but also don’t forget about the past and the future.

A robust EH&S program will include four main ingredients. You must have these four components as a minimum:


  • Federal, state, and local regulations
  • Address multi-media issues like air, soil, water, waste, and more
  • Permits

Health and Safety

  • OSHA regulations for safe work practices and procedures

Risk Reduction and Liability Protection

This risk reduction and liability protection component is what we find lacking in many facilities. And the antidote is to re-focus your strategy as we mentioned before on your:

  • Past (learn from it)
  • Present (protect it)
  • Future (secure it)

This way, you can identify liabilities and get rid of them before they become time-consuming and expensive exposures that must be remediated… or subject you to significant fines and penalties.


  • This involves all of the above and more (training, monitoring, reporting, etc.)
  • What many facility managers forget is that being in compliance one day doesn’t mean you always will be. And you have to be vigilant in monitoring that.

A Strong EH&S Program – the Finer Details

Aside from all of the above, a strong EH&S program must:

  • Be proactive, not reactive
  • Promote elimination, rather than control
  • Address everyday routine operations, non-compliant events, and emergency issues
  • Be goal driven to promote continuous improvement

At the End of the Day

You might think you have a strong environmental, health and safety program in place already. But I urge you to look at it closely using the standards above. As a facility manager these days, you wear more hats than ever.

Having a robust EH&S program that considers all these elements will ensure your facility not only runs smoothly 24/7 but stays in compliance 365 days a year. That earns you the support of your team and kudos from upper management.

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