Are There Gaps in Our EHS Management System?
Posted on April 13, 2020 | in Operational Risk
The global COVID-19 pandemic has had a massive impact on workplaces, as levels of operation change or even cease due to lockdown measures, and employees find themselves more geographically spread out than ever.
Unfortunately, these challenges may also reveal gaps in our EHS management system that we didn’t know about before. During “normal” times, we may find workarounds for some of these weaknesses, and might not feel the urgency to address them. But the disruptions many workplaces are now experiencing can not only expose those weaknesses, but potentially amplify them. The danger is that under the stress of a crisis like the current pandemic, small gaps can become chasms, and our safety performance can suffer.
Let’s take a look at a few key areas of EHS management so we can assess how our systems are holding up during these trying times.
How easily are we able to access our most important EHS information? For example, can we verify the status of outstanding corrective actions? Can we review completion percentages for training, and see at a glance who still needs to complete their training?
One very important consideration involves the accessibility of our JSAs and other risk assessments. As we discussed in a recent blog post, it’s even more difficult to manage our job safety analyses (JSAs) and other risk assessments during times like these. Having fewer people available to perform job tasks may force us to change the way jobs are performed, which also triggers a need to revise the corresponding JSAs.
Faced with these operational and personnel changes, we may find ourselves forced to assign less experienced workers to jobs usually conducted by others. This makes it even more critical to keep our JSAs current and provide our workers with access to them so they have the information needed to perform the jobs safely. Risk management software solutions that enable us to efficiently manage JSAs, bowtie analyses, quantitative risk analyses, and verify that critical controls are working as planned can help us overcome any gaps.
We may also be finding gaps in our chemical management systems, especially when it comes to maintaining a safety data sheet (SDS) library and ensuring our workers have access to SDSs during their workshift. This is especially important now considering the increased use of cleaning and disinfecting products — some we may have never used before — to prevent contamination by SARS CoV-2 virus and COVID-19.
In addition, the frequency and duration of exposures due to increased cleaning and disinfecting may now result in even consumer cleaning products being subject to OSHA’s HazCom Standard. This means we need to need to make sure we have product SDSs, can confirm our employees know how to access it and understand cleaning product hazards. We need to ask ourselves, “Is our current chemical management system able to provide these safeguards when we need them?
Even under normal conditions, completing certain common EHS tasks can be challenging.
Inspections are a great example. There are inspections mandated by regulations, such as hazardous waste storage inspections required by EPA’s Resource Conservation and Recovery Act (RCRA) or forklift inspections required by OSHA, as well as routine safety best-practice inspections. In either case, they offer a direct means of assessing whether we are operating safely and efficiently, and that the reality on “the ground” matches what it should be on paper. Reliance on paper or outdated legacy software systems can make completion of inspections difficult, and ultimately jeopardize the effectiveness of our management systems. If scheduled inspections are not getting done right now, it may be time to look into the benefits of a modern software-based inspection management system, the best of which enable the use of custom inspection checklists from anywhere using your mobile device.
It’s also very important that we complete our incident investigations for workplace injuries, near misses/near hits/close calls, chemical spills, and environmental releases. Once again, this is sometimes a regulatory obligation, as it is for injuries and illnesses that meet the definition of “recordable” under the Recordkeeping Standard. On a more general level, we need to be able to capture enough details about workplace incidents and their causes to reduce risks and prevent them from recurring. If we know of gaps in our incident reporting since the COVID-19 pandemic started, we might consider looking into software-based systems that facilitate incident reporting through simple and intuitive mobile apps.
EHS policies and procedures need to be built upon a strong EHS culture. That means staying in contact with all of our workers, and keeping them informed of open action items and other safety activities.
Many of us lucky enough to still be working are working from home right now. Web conferencing tools have enabled us to have our virtual meetings and send and read emails, but maybe something still seems to be missing?
If we’re not feeling as connected with our people as we’d like to be, EHS software can help there, too. Safety Meetings software can help us schedule our meetings, circulate agendas, and keep track of important developments. Built in corrective actions and compliance management solutions with automated escalating notifications can help minimize the chance of missing important due dates by directly alerting employees with important assigned responsibilities.
Is it the Pandemic’s Fault?
It might be easy to chalk up any problems we’re experiencing with our EHS management systems to the effects of the COVID-19 pandemic. Granted, the pandemic has had catastrophic effects on many facets of life, especially and including our workplaces. It’s also a given that everything that’s happened in recent times has created anxiety and shifted our focus to other things, some of which may be the survival of our very business and livelihood, itself.
Still, I’d argue that effective EHS management should be “built to last.” After all, one of the most important considerations for any safety professional is emergency planning – making every effort to ensure that we’re prepared for emergencies and business disruptions, and are thinking about how to protect the safety of our workers in the most challenging of times. In other words, an effective EHS management system needs to work all of the time, and in fact, it’s even more important that it works during a crisis.
The point here is, of course, not to blame anyone. We’re all human, and we’re all dealing with these chaotic and uncertain times. But we have choices when it comes to the things we can control, and our response will go a long way toward putting ourselves and our workplace safety systems in the best possible place for the future.
How we structure our EHS management systems is one of the things we can control. If we are seeing weaknesses in our system, now is the time to fix them. The improvements we make today will bring a safer workplace tomorrow.
Let VelocityEHS Help
VelocityEHS Solutions can help you control and optimize all facets of your EHS management systems including audits, inspections, risk management, safety meetings management and chemical/SDS management. Contact us anytime to learn more.
Until next time, take care.