6 Mistakes You’re Making With Your EHS Management Plan
How does your EHS management plan stack up? Find out if you’re making these six common errors. And find some insider tips for making your plan stronger.
By Cory Sander and Pat Kneip
As an EHS manager, you’re tasked with creating your company’s environmental plan, health and safety plan, or both. You’ve probably searched for EHS management plan samples and templates for inspiration. But, ultimately, it’s up to you to get all those details right. And, oh yeah, carry out all your other daily tasks, too. So how does your plan stack up? See if you’re making these six common mistakes.
You didn’t set clear objectives for your plan.
Many plans lay out plenty of tasks and regulatory requirements, but few take a step back to look at the big picture. A good plan answers this question: What goals am I trying to achieve beyond basic compliance?
Maybe you want to reduce environmental impact by recycling wastewater. Stop sending things to the landfill, so your company can market itself as zero waste. Or simply reduce overall operating costs. Document these specific goals—and how you’ll achieve them—within your plan. This creates a powerful combination of strategy and tactics.
There’s no feedback loop to drive continuous improvement.
No plan is perfect, so it’s crucial to create a formal avenue for plant operation staff to provide feedback on your plan. This might be anything from an anonymous suggestion box to a quarterly meeting.
Why is it important? Here’s just one example: A regulatory requirement calls for monthly inspections, but the corporate leadership team wants to knock it out of the park by upping the frequency to daily. Your operation team wants to make everyone happy, but they quickly realize it’s not possible to make production goals and do meaningful daily inspections.
An open feedback loop allows everyone to identify and solve this problem before there are missed production targets or sloppy inspections. In this case, the solution might be as simple as meeting in the middle with a weekly inspection.
Your document management system is poorly organized.
Dusty files cabinets, messy desks and overloaded clipboards don’t count as a document management system.
Everything in your environmental or health and safety management plan references another document. It might be your air permit, waste training plan, work instruction or a log from the paint booth. Each of these items should be easy to find—whether that’s within EHS software or a well-organized file cabinet.
In fact, you should note the location of crucial documents and paperwork right in your EHS plan. If you face an unexpected audit, you may need to produce key documents on the spot.
It hasn’t been updated in two years (or longer).
This isn’t a one-and-done exercise. Regulations, facilities and staffing change all the time, and your plan should keep pace. Think of your EHS management plan as a living document and record a schedule for updating it (at least once a year) right in the plan.
You’ll want to review your plan alongside any regulatory changes that might affect your facilities. And go through any changes in your facilities themselves. Did you expand? Add a new machine? Or simply have enough staff turnover that you need to re-think who executes which parts of the plan?
This is also your chance to make sure you didn’t miss any requirements last time around. It’s easy enough to do, especially if your plan covers multiple facilities. How do you make sure you catch everything? Consider an audit—either internal or external—for every facility covered by your health, safety and environment plan.
Your plan lacks specificity.
A plan isn’t useful unless it’s specific. New employees should be able to review the plan and find everything they need to execute. You need to answer two questions for every item in the plan: Where is this requirement coming from? And how do we as a company carry this out?
Let’s say your plan references stormwater sampling. First, you’ll need to include a regulatory reference and outline where to find your company’s stormwater permit. Second, detail exactly where to find the work instruction for carrying out that sampling. Finally, name names and the recurring time frame: John Smith conducts semi-annual stormwater sampling at the Atlanta facility.
Even if you have two people trading off a task, make one person ultimately responsible for completion and name only one responsible party in the plan. Some larger facilities have enough turnover that naming specific individuals can be tricky. In this case, you can use a very specific title—say maintenance manager—as long as everyone would know who holds that title.
No one knows about your plan.
Poor communication might be the biggest EHS management plan sin. You can have the best plan in the world, but if it’s hidden on your computer’s hard drive, it isn’t going to drive results.
Communicate your plan early, often and in multiple formats. Email it to all affected staff. Hold a meeting to review plan highlights. Post copies on the company bulletin board. Or hand physical copies to everyone involved. Better yet, all of the above. Most people need to hear a message four or five times before they begin to retain it.
All this communication also gives you the chance to field questions and gain buy-in on your plan. Explain why it’s so important for you to have those readings and inspections reports. And how the plan ties into the company’s overall success. Repeat this process every time you update your plan.