Make HSE a Priority

An effective health, safety and environmental management system will improve workflow and HSE performance

By Rebecca Pehler

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An important discussion is occurring both globally and domestically about the need for a management system (MS). What is an MS and why should you be concerned with it? An MS is a collection of workflows that defines a business.

A business' sustainability and, in many cases, its license to operate are defined by its Health, Safety and Environmental (HSE) commitment and policy. A company's response to HSE issues affects employees, contractors, stakeholders and the surrounding community.

Management is seeking reliable means to ensure that HSE issues are addressed. By having an MS in place, these HSE issues are evaluated and revised on a more consistent basis.

The MS has the potential to play a key role in evaluating workflow performance , thereby ensuring the health and safety of employees and personnel, maintaining regulatory compliance, enhancing business reputation within the community, satisfying customers and promoting profitability.

Regulatory incentives are motivating businesses to examine the benefits of implementing an EMS. The Texas Commission on Environmental Quality (TCEQ) may expand voluntary participation in the EMS Integration Plan to include an EMS requirement in a business's permitting process. The EMS Integration Plan and its regulatory incentives are defined in the State Administrative Code 30, Section 90 (30 TAC 90).

The State of Texas, in partnership with EPA, is the first state in the nation to offer an EMS regulatory incentive program. This Texas-based program has the potential to be used as a model for similar efforts in managing environmental issues in other states.

A key standard

ISO 14001, a worldwide standard issued by the International Standards Organization, defines EMS issues in business, including emergency response requirements and preparation for environmental incidents. ISO 14001 covers, among other things, implementation, monitoring, measurement, corrective action, procedures, standards and management. The value of the ISO 14001 standard is that it focuses on awareness of environmental impact of workflow, not job function, as a part of business.

When deciding the extent of coverage for the MS, your company needs to answer several questions. Will management commit to and actively support having an MS in place? If so, will the MS center around an environmental standard or one that also applies to health and safety? If the decision is to have an integrated HSE MS, then any overlap between the standards must be considered during the planning stages. How will this overlap affect maintenance of the MS?

When the EMS is expanded to include health and safety, everyday business decisions will be driven by the HSE MS. Management will then have a more focused and cost-effective use of resources. Additional benefits include, but are not limited to: improved risk analysis, consistent documentation practices and minimization of environmental impact.

The EMS and HSE MS share several components that are central to a business, regardless of the type. The individual and collective business workflows are covered by these core components, which include: objective- and target-setting; risk management; policies, plans and setting of the business direction; organization and resources; standards and procedures; self-assessment or audits; implementation, monitoring and corrective action; and management review.

These components describe the collective workflows and objectives of the business, while simultaneously responding to changes in both business and regulatory climates. They provide a critical self-assessment tool to determine whether continuous HSE improvement is occurring, and a mechanism for communication to relevant business stakeholders. The components of the MS also provide value to business management in monitoring and measuring HSE performance and achieving continuous improvement.

The starting point

In setting up an effective MS that is based on workflow decisions, five components must be present in each stage of design.

Define the HSE issue.

Make sure that authority and responsibility lines are clearly drawn so as not to interrupt workflow. Minimize the number of authorities required in the review process. Maintain an HSE Commitment and Policy statement. Ensure that the HSE issue being evaluated does not conflict with the basic components of the policy statement.

Set objectives and targets.

Management should document and communicate the company's objectives and targets to both employees and contractors. This can be done at HSE meetings, through company newsletters or the company's Web site. HSE training should include a module explaining how the company's objectives and targets are determined, communicated, reviewed and updated by management, and how the employee/contractor has input into setting them. Management should formally document all of these things in the HSE MS manual.

Document compliance requirements and performance.

Establish an assurance process for a person or team to monitor compliance requirements. The responsible individual or group should document, communicate and track compliance performance within the business. Make sure the authority of the person or team assigned this responsibility is clearly defined.

Communicate and document the importance of HSE.

If employees are not aware of HSE's value to the business, issues that need to be addressed may not be noticed. Provide continuous training for the MS. Document training and competency testing on HSE components of the MS completed by all employees, including those in management.

Allocate HSE resources.

Correlate all HSE data findings, both conformance and nonconformance, back to the core components of the MS. Management should commit to a regular review of the HSE data and information. This review process should be documented in the MS manual.

Implementing the MS you have designed involves five stages.

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