Management buy-inYou must have management buy-in for an MS to succeed. Management should promote the program and help define the key components. These components include: organization and responsibilities; employee participation and ownership; self-assessment; monitoring and measurement; and management reviews.
The MS manual should communicate a message of commitment. Management should designate a team that is responsible for implementation, monitoring, performance evaluation and management review of the program. The authorities and responsibilities for each member of the team should be defined.
To determine compliance, key performance statistics should be regularly monitored and measured. Incorporate these results into corrective and/or preventive action, reporting and management review.
Set annual business objectives and targets. Input for adjusting these goals should be based on an assessment of environmental impacts and HSE risk assessment; compliance with regulations; compliance with workflow standards (for example, ISO 14001); and waste reduction and energy conservation.
Identify and assess risk
You should identify environmental impacts and determine the basis of risk assessment. Define the type of environmental impact and area or media affected, such as air, noise or release to water. This will aid in identifying key contributors (departments or areas) to the overall workflow. Management should use this information when forming the implementation team. This ensures that you have an accurate representation of overall business workflow.
Communicate and document the significance of the environmental impact (low, medium or high), including health and safety impacts. Incorporate a procedure to review and update this information annually.
Identify the controls in place to limit the impact on the environment. Determine the tolerable level of HSE risk the business will assume. Define levels of risk with respect to employees and contractors, business operations and the company's reputation in the surrounding community.
Key environmental impacts include: air emissions; releases to water; waste management; land contamination; raw materials usage and natural resources; and environmental issues important to the surrounding community.
Issue a policy statementUse information about environmental impacts to issue a policy statement (EMS or HSE MS) for the business. Articulate the policy as defined by management to comply with HSE regulations, to protect the environment and minimize environmental impacts, and to continually improve performance. Set HSE objectives and targets, as well as mechanisms for monitoring and measuring HSE issues. Solicit input from stakeholders when assessing MS performance. In preparation of the business plan, review the company's objectives, which should include the HSE Policy and Commitment statement.
Communicate HSE performance to employees and stakeholders. Business management should review performance annually. For maximum effectiveness and buy-in, review HSE performance in partnership with work groups, such as unions and contractors.
Management should review compliance and make annual adjustments in response to both internal and external business operations. Internal audit results should have input into this process.
Self-assessmentYour company should assess the performance of its MS. Define and review HSE performance from previous years. The review should cover not only the performance achieved, but previous years' objectives and targets. Document the successes and failures in meeting your goals for continuous HSE performance improvement.
Communicate, review and document management practices and procedures that succeeded in achieving continuous performance improvement. Evaluate input on performance from different departments, customers and the surrounding community. Review any existing procedures for dealing with contracting and procurement to determine their efficacy in enhancing business performance.
Determine compliance by a review of the existing process. Investigate and resolve issues of noncompliance of the company's workflows. Does corrective action work in a timely manner to identify, review, resolve and follow up on the noncompliance issue? Document and communicate responsibility and accountability for workflows within the business. Establish teams to implement, maintain and improve performance of the business. Develop and maintain an MS (EMS or HSE MS) documentation manual all personnel can use as a central reference. In addition to defining the components of the MS, this manual should contain references to standards, operating procedures and work instructions.
Are corrective action results used as input to reflect and respond to changing business conditions? Is this process documented in the business MS manual? Does the business have a stand-alone document that defines the business's objectives, targets and goals? Is this document located where personnel have ready access to it?
Final implementationDefine a document control system for the business. All procedures should be available and accessible to employees. They should be regularly reviewed or revised, controlled and managed.
Communicate all training requirements for specific workflows. Define the skills and proficiency that are expected of the employees performing the workflow. Establish a managed training system to track each employee's level of competence. Maintain a training schedule and document employees' training.
Measure compliance by an auditing process to assess the effectiveness of business work processes. Are objectives and targets, as well as compliance with regulatory requirements, being met by the business? Are monitoring and measuring methods effective in gathering information about performance?
Internal audits enable a business to assess whether performance objectives and targets are being met. If they have not been met, make the necessary adjustments to achieve these goals. Business management should commitment to this in its HSE Policy and Commitment statement.