Environmental, Health and Safety (EHS) Leadership Documents and Management Tools
Author: V. J. Marchsani, Ph.D.
Many companies have a plethora of EHS management documents such as mission and vision statements, policies, standards, guidelines, procedures, practice, programs, targets, goals, objectives and plans. Unfortunately many see the creation of these documents as necessary evils, a checklist of what needs to be completed to create a management system. How these documents fit together is not often clear. This article will help provide an understanding as to how each of the documents interacts in a seamless fabric. From the company belief regarding EHS matters to the job responsibilities of the worker sweeping the manufacturing facility floor, the documents act as tools to successfully manage the EHS function.
In establishing an integrated management system companies typically begin with the creation of a mission statement. Gathering people, and explaining that their role is to create a mission statement is not an easy task. Typically the assumption is made that everyone in the room knows what a mission statement is, and they begin asking the group for ideas, words, that are put on a board in an attempt to create the statement. While most people are happy to be invited, many wish that the process would complete quickly so they could get back to more meaningful work. After all, no one will look at the mission statement beyond the first week of its development; and it will disappear into a book and be placed on a shelf for years to come.
This perception of, “Lack of value added” associated with the preparation of a mission statement is also judged to apply to a vision statement, a policy, a standard and the like. Often words like, “Can we get by all of this, and move to the real work? In time we shall hire a consultant to help us create new mission and vision statements which will run the same course.” The importance of a mission statement, a vision statement, policy and the like is too often missed because their utility and value are not understood.
As with any new endeavor, definitions are critical to success. For example: a mission statement may be defined as the reason a group or organization exists. If a group knows how to do its job, why does it need to identify what it already knows how to do? Good question! The answer is that a mission statement focuses a group. If the group wishes to take on a new activity which is outside its mission statement, it should not take on the activity unless or until the mission statement is modified to reflect the new activity. The reason this is important is that a company which has committees that do not have mission statements runs the risk of having multiple groups working on the same thing. This duplication of effort is usually costly and non productive. In addition, where mission statements exist, company leadership can clearly see if and where topics and issues important to a company are being addressed. When new issues arise, company leadership can select the internal group to best address the issue.
Similar difficulties exist with regard to vision statements. Why should a group or committee spent time to create a vision statement? Here again definition is critical. A vision statement identifies the maximum potential of the group! If the group were to do the best job possible, extend its mission statement to be the absolute best at what it plans to do, it will have achieved its vision statement.
Unfortunately the word policy has taken on many meanings. It is the mantra upon which the company is built for an identified area of management, e. g. EHS management. Company EHS policy, whether it be EHS or separate policies for E, H and S is the license for the EHS function to operate. In addition, a policy is not a policy until it is in writing and signed by the president of the company. If this is not the case the policy represents a thought or idea. Often people will say, “We have a policy concerning that.” Are they identifying a policy, or is it a practice, or perhaps a procedure? The obvious question is, “What does it matter?” It matters a great deal. Policies communicate company beliefs. If members of the group creating the policy have different definitions for the word policy, each member of the group is attempting to create something different. In working to create policy, hours and even days can be lost unless everyone is agreed to the definition of policy. Policy, standards, guidelines, procedures, practices, programs and the like are all different; and it is important that they be defined and their differences be understood.
In creating a policy one needs to back away and consider the hierarchy associated with effective management. There is a need to find the company belief concerning a specific topic. For example: what is the company belief regarding how it should manage EHS matters. Once that belief is understood it should be put into a format where it becomes a policy. A policy should be one sentence in length; and followed by the words, “In carrying out this policy the company shall.” In this way the policy stands alone, and the company may list the many things that will be done to carry out the policy. One of the ways listed in carrying out the policy should identify a periodic audit to see if the policy is being carried out. The document should identify who is responsible for adhering to the policy, and who is responsible for carrying out the policy. Updating of the policy should occur at least every three years.
Many companies have created an excellent document which describes their organization and identifies what the company has accomplished in the EHS area. This is often identified as their EHS policy. In reading some of these, “Policies”, and using the above approach for creating a policy, the policy sentence is often found half way through the second or third paragraphs of the document. This is not to say that this form of policy creation is wrong, however, keeping the policy to a single sentence followed by company activities to carry out the policy provides a cleaner and clearer document; and the policy is easily recognized and understood. Some companies have created an internal document which helps in the understanding of each of the bullet marks which identifies what a company will do to carry out its policy. These descriptions are helpful in understanding non stated sub-elements of a policy. For example: While the wording of an EHS policy may not say anything about smoking in the work place; the fact that the policy states that the company will take foremost account of the health of employees implies that smoking in the work place is not acceptable. Therefore, a standard or practice may be written concerning smoking in the work place since the policy states that the company will take foremost account of the health of its employees.
Documents similar to company EHS policy such as company standards, procedures, practices, targets, goals, objectives and the like need to be created, and the definitions of these terms made clear. Once all the appropriate documents are created, including employee job descriptions, and their annual targets and stretch targets; all of the documents must be weaved together into a seamless management fabric. This is done so that measurable progress can be made such that the Environmental, Health and Safety Management Plan (EHSMP) to achieve goals and objectives through the implementation of procedures, practices and the like can be accomplished. The process to integrate the management documents follows:
• Identify the company belief about EHS. For example: a company believes that the environment should be protected and the health and safety of employees needs to be ensured.
• Come up with a sentence that best describes the company belief about protecting EHS.
o The following is an example of a Company EHS Policy: “It is the company policy to protect of the environment and ensure the health and safety of all employees at all company locations.”
• List the ways the company shall “Carry out the policy.”
o One of the ways could be a call for a reduction in waste generation.
o A company standard could be created requiring a reduction in waste generation. Note: a company standard should be considered to be similar to government regulations while a company policy is similar to government legislation.
o The standard could call for each facility to identify an annual numerical waste reduction target, and a plan to meet that target.
o These location generated numbers can be rolled up to express a company target for an annual reduction in waste generation.
o The results of the waste reduction effort can be periodically shared with senior management.
• Develop a guideline to carry out the company waste reduction standard.
• Environmental procedures and practices could be developed so that, once followed, they would bring about a reduction in waste generation.
• Form guidance committees with mission and vision statements which clearly identify their role in the waste reduction process.
• Create job descriptions that are consistent with all of the above such that waste reduction becomes a way of life for employees. In other words they own it!
o Annual targets and stretch targets can be created for the employees such that the targets foster employee involvement in waste reduction.
• Create a 5-year EHSMP that focuses on satisfying the environmental waste reduction among other targets associated with the EHS policy, the top of the environmental management hierarchy.
o The EHSMP would have, as part of the plan, a 5 year waste reduction goal, 1 year waste reduction objectives and numerical targets.
o The 1 year objectives would include a list of tasks, responsible parties, work products and expected delivery dates for the work products to be completed.
o The EHSMP should include a 5 year long term goal and 1 year short term objectives for each of the ways the policy will be carried out.
The above process focuses on a reduction in waste generation because it is one of the ways listed in how the EHS policy will be carried out. The section regarding how the Health and Safety section will be carried out will follow a similar protocol. Each of the other ways the policy will be carried out; and identified in the policy, will follow a similar process of the development of standards, guidelines, procedures, practices, committee formation (with mission and vision statements), goals, objectives, programs and the like. The EHSMP will contain one page for each of the objectives identified.
Company policy, standards, guidelines, procedures, practices, goals, objectives, targets and the like are not stand alone documents. If they exist in a company as stand alone documents their value will not be recognized; or will be diminished. Properly prepared, supported and integrated into a management system; these documents foster confidence and success within an organization trying to build, improve and move their EHS program forward. It also sends a clear and strong message of EHS commitment to employees and the community. In addition, and most important, a properly implemented system should result in an improved environment and protect employees. This in turn will reduce company costs.
For additional information on this topic contact Dr. V. J. Marchesani at EHSInt@aol.com; or call, in the United States, 484-354-2196.