Are You Managing Your EHS Actions, or are They Managing You?
Posted on September 6, 2019 | in EHS
The job of an EHS professional is never over. There’s always work that needs doing, including an ever-growing list of tasks we need to complete to address risks and maintain effective workplace safety programs. Making life more difficult, the work has a way of multiplying. Sometimes, it seems that for every item we cross off the list, three more take its place!
A common way to can talk about the EHS work we do is to call them “actions.” Anyone in the EHS world for a while will hear this term and recognize their importance to EHS management, but actually getting a handle on the sheer number of actions that must be completed is another matter. We need to prioritize our actions, assign them to the right people, track them to completion, verify their effectiveness and be able to report our progress to our workforce and other stakeholders. All of that can be challenging in terms of both time and effort.
The good news is that it can be a lot easier with the right approach and the right tools. Let’s talk more ways you can improve your action management systems.
Types of Actions
First, we need to understand the different kinds of actions we perform. Some of the most important and common kinds of actions are described below:
Corrective Actions – These are probably the actions many of us think of right away. There are good reasons for that, since many of our everyday EHS tasks reveal issues we need to fix. We call those planned fixes “corrective actions.” For example, almost every time we do an inspection, conduct an audit, or review training or regulatory compliance status, we end up with corrective actions. We get more when we perform risk analysis activities such as Job Safety Analyses (JSAs), implement Management of Change (MOC) processes to review proposed changes to operations, or have employees bring issues to our attention. All of these additional EHS management activities mean even more corrective actions to address.
Preventive Actions – Not all actions we manage are, or should be, reactive measures to correct safety risks that already exist. One of the most important classes of actions, preventive actions, seeks to prevent risks from arising in the first place. For example, if we don’t do preventive maintenance on monitors used to detect the presence of air contaminants at dangerous concentrations, employees may suffer ill health effects from exposure. This scheduled maintenance would be considered a preventive action. It should be noted that for some facilities, especially those subject to OSHA’s Process Safety Management (PSM) standard due to their handling of highly hazardous chemicals, preventive maintenance is also a strict regulatory requirement.
Corrective and Preventive Actions (CAPA) – Of course, the reality is that it’s hard to cleanly separate corrective actions from preventive actions. One way to think about it is that both of those actions are really about prevention. It’s just that corrective actions are intended to prevent recurrence, while preventive actions are intended to prevent them from occurring in the first place. CAPA, as a term and as a practice, recognizes the strong relationship between prevention and correction and integrates them into a single improvement process.
Compliance Actions – We can think of compliance actions as things we need to do because specific regulations say we need to do them. For instance, EPA’s Resource Conservation and Recovery Act (RCRA) regulations require large quantity generators (LQGs) of hazardous waste to conduct weekly inspections of their waste storage locations. This particular example would also be an example of a preventive action, since a major reason for conducting the inspections is to identify storage issues or container integrity problems that may result in hazardous waste spills if left uncorrected.
An Essential Part of Your Safety Management System
The importance of managing actions is increasingly recognized in international standards such as ISO 45001. Section 10.2 of the standard which covers “Incident, nonconformity and corrective action” states that organizations need a process for reacting in a timely manner whenever there is an incident or nonconformity. According to definitions within the standard, “incidents” include close calls and near misses, and a “nonconformity” is essentially any instance when the company fails to do what its own management system policies and procedures require.
The standard also states that management needs to “evaluate, with the participation of workers and the involvement of other interested parties, the need for corrective action to eliminate the root cause(s) of the incident or nonconformity.” This highlights a key feature of ISO 45001, which is its strong emphasis on employee participation. In explanatory notes, the standard also clarifies that non-managerial employees need to be involved in the process.
According to the standard, an organization also can’t simply complete the action(s) related to a particular incident or nonconformity and call it a day. ISO 45001 directs them to determine if similar incidents have occurred, or could potentially occur. It also states that organizations need to document the results of actions taken and evaluate their effectiveness. This helps ensure that management is looking beyond the immediate problem at hand, and is actually making the effort to validate the effectiveness of actions.
At this point, we should clearly understand that managing actions is very important to safety performance, but that doesn’t mean it’s easy.
At any given time, an organization is likely to be managing numerous action items in various degrees of completion. That’s why you need to prioritize your actions based on the potential risks of not addressing them. This will help you focus on the most important actions at any given time so that you’re spending your time where it’s needed most.
Another important part of actions management is assigning them to the right people, which will vary depending on what needs to be done. For example, actions that involve repair or adjustment of equipment may prompt us to include our maintenance personnel. Other actions may require monetary funding, which means that financial decision makers may need to be involved. Be sure to think carefully about who needs to be involved in managing actions to avoid potential snags in the process.
You also need visibility into the completion status of your actions so that you know when follow-up is needed, and have the ability to share results with your EHS management team. Knowing the status of actions will also help you know when it’s time to take the important but often overlooked step of actually verifying that actions have been completed exactly as planned, and that they have been effective. If you find that actions that aren’t working as planned, modify them with employee participation and then re-evaluate.
Even if you follow these guidelines, the sheer number of actions to manage can seem overwhelming, especially if you lack a single system for capturing and managing them. Having a system that captures and funnels all of your different actions into one place can dramatically simplify management and follow-up. A purpose-built corrective actions software solution can be a big help here.
The Heart of Your EHS Culture
Improving our actions management systems will go a long way toward the health of your EHS culture. Prompt completion of actions demonstrates management’s commitment to reducing risks, and focusing our attention beyond immediate incidents increases the likelihood of identifying other relevant risks before more accidents occur.
Worker involvement improves the odds that actions will be effective, since workers know more about their job tasks and associated safety risks than anyone else. That’s one of the major reasons why international standards like ISO 45001 emphasize involvement of all employees in the EHS management system, including corrective action development.
Developing and completing corrective actions with the participation of employees also drives continuous improvement of the whole process. The more frequently we can document that actions are effectively managed and completed with employee involvement, the more likely it is that workers will buy into our EHS culture — making every facet of our management system that much better.
Looking for more detailed guidance on how to improve your actions management? Check out our free on-demand webinar by clicking the link below.
Let VelocityEHS Help!
We design our award-winning EHS management solutions based on feedback from EHS professionals like you. That’s why our Corrective Actions solution is carefully integrated into each of our EHS software products, including Audit & Inspection, Incident Management, Safety Meetings, Management of Change, Risk Analysis, and Compliance Management, so you can have a single, seamless system to capture and manage actions generated by all of your EHS tasks.
You can also easily assign actions for individual checklist items when nonconformances are identified, and to be able to verify completion of actions during audit follow-ups.
Interested in learning more? Watch this video demo of the VelocityEHS platform, or contact us at 1.866.919.7922.