A Look at Management Systems for EHS Compliance
Corporations and government agencies are continually seeking ways to improve their environmental, health, and safety (EHS) performance. This quest for better performance often leads to the realization that there is a need for an organizational shift from reactive management towards proactive management of EHS issues. Turning this realization into action however, is not easy; it requires a methodical, well-organized approach.
To support this shift, many organizations are adopting EHS management systems (i.e.: OHSAS 18001, ANSI Z10, ISO 14001), which offer a more structured approach to management of EHS issues.
These systems involve many requirements that induce the organization to understand, define, and implement numerous inter-related system elements.
Compliance Management: a Critical Element of an EHS Management System
‘Compliance management’ is often considered the most important of the EHS management system elements, but it is also one of the most challenging elements to implement effectively. This central component of the systems approach requires EHS departments to track and maintain extensive libraries of ‘legal and other requirements’ and permits, and of course prove compliance to those requirements. It also involves understanding, documenting, and evaluating compliance.
The Overall Benefit of a Management System
While essential, compliance management alone is not the core objective of the management systems approach. The often overlooked goal of a SMS/EMS is not just meeting each of the required ISO/OSHAS elements individually and then obtaining the relevant certification, it is to improve overall health, safety, and environmental performance. Thus, the real value of the management systems approach is not simply fulfilling the individual requirements; it is found in the overlap and interaction of all the system elements.
When companies come to this realization, they can take advantage of the full ‘system’ benefits. All the elements of a SMS/EMS then work together to achieve the common goal of improved performance. Compliance Management is a critical common thread connecting all these elements together. We will now examine how to improve compliance management in a way that is beneficial to your entire management systems approach.
Challenges of Compliance Management in the SMS/EMS Approach
Subscribing to an EHS management system has a myriad of benefits, but requires a commitment and investment from the organization and its EHS managers to ensure that standards are followed, and requirements are met or exceeded. As an example, part of compliance management is tracking and maintaining a library or inventory of ‘legal and other requirements’. This time-consuming administrative exercise is one that often goes to waste. With good intentions, a company may begin documenting all of their requirements, but then abandon the effort and reduce the information to a binder gathering dust on a shelf, or an electronic file left untouched on someone’s computer. The requirements inventory never receives the attention or maintenance it requires because there is no effective system in place.
Running an effective compliance management program is not easy; the above example is but one of many possible scenarios that may hold an organization back. With that in mind, let’s isolate the key compliance management challenges an organization can face as part of their SMS/EMS implementation.
Key Challenges of Compliance Management in the SMS/ EMS Approach:
1. Maintaining an up-to-date inventory of all ‘legal & other requirements’ that includes a record history of all changes made to the list over time.
2. Recording the actions associated with each requirement and ensuring appropriate management of change when the requirements change.
3. Effective tracking of findings & corrective actions for addressing non-conformances as they relate to specific requirements.
4. Developing an effective and visual monitoring and measuring system for tracking performance of the complete compliance management program.
5. Integrating your compliance management program into the other elements of your safety
To elaborate on challenge #5, it is important for companies to recognize that an optimal compliance management program is not only run efficiently as a standalone component, but should efficiently integrate with the other components of the SMS/ EMS. That is the true nature of the management system; achieving a holistic and integrated ‘world view’ of your EHS programs.
The Roadblock: Inefficient, Disconnected Data Systems
For organizations implementing an SMS/EMS, implementing a compliance management program that overcomes the challenges listed above can be a daunting notion. It is important then for these organizations to assess what may be holding them back. Do your data management systems help or hinder your compliance management efforts? It is clear from reviewing the challenges above that an effective SMS/EMS compliance management program cannot be executed without well-managed, accessible, and dynamic data. Good data will inform EHS managers whether requirements and performance goals are being met, and, even more importantly, can offer invaluable insight into shortcomings and problem areas.
The most common roadblocks to effective compliance management are the tools used to track and collect data from an organization’s various EHS programs. These programs are often managed with different, inefficient, and disconnected data management systems, such as spreadsheets, home-grown databases, and paper files. Different departments may even be responsible for different pieces of the data, with each using their own isolated methods of recording information. More sophisticated companies may have some compliance software or HSE software in place – these may include medical case management software, HSE compliance software, quality control software, safety software, EMIS software, medical clinic software, and health clinic software — but these systems are often still disconnected from one another and cannot effectively support a holistic compliance management process. This type of disjointed approach often relies on inefficient and possibly manual gathering of information.
Solution: Integrated, Automated Data Management – HSE Compliance Software
To support a complete and effective compliance management program, it is critical to consider how the organization can integrate, organize, and manage all components into the same database. An ideal compliance management system process allows for cohesive, holistic management of EHS data across functions and even departments. All the system elements should be interconnected and integrated, thus promoting effective communication, efficient data sharing, good data quality, and valuable reporting.
An integrated, automated system will allow you to:
1. Set up automated workflows and processes that promote standardization across EHS functions.
2. Seamlessly share data between safety programs to inform business intelligence.
3. Link compliance inventory and tracking to each component of your safety program to efficiently and automatically update information, due dates, completion statuses, etc.
4. Automate notifications and reminders to ensure that requirements are satisfied in a timely and complete manner.
An organization cannot realistically take the leap from the disjointed to the holistic, well-organized system overnight. This transition is a process that requires careful assessment of current practices, documenting of requirements, and evaluation of possible solutions.
Once the initial work is done and you are ready to evaluate solutions, it is critical to ensure that the HSE compliance management software system you select does not only handle compliance management alone; the ideal solution should allow you to track, manage, and analyze the data from your various programs under one roof. Having this synergy between components will not only prove invaluable for effective compliance management, but will greatly contribute to helping you achieve the overall goal of improved performance.
Compliance Management Assessment – Workflow Considerations
Before deciding to implement HSE compliance software, take the time to evaluate your current compliance management processes thoroughly. This will help you to determine gaps in efficiency and identify opportunities for improvement. To get you started, below is a list of the typical steps in a compliance management workflow. As you review, consider how you are managing each step within your organization, and whether you have cohesion between all steps.
1. In each piece of legislation pull out the specific clauses/requirements that affect your workplace and organize in central location. (i.e. OSHA Part 5, section 2, clause a.)
2. Build complete requirement and permit library/ inventory.
3. Review workplace to assess compliance to all legal requirements and permits.
4. Create action plan for how to continue to complete legal requirements and permits or to correct any non-compliant actions within the organization.
5. Complete and close out action items in the plan and follow up on any open items.
6. Review total compliance risk through reporting and tracking. This step is crucial to identify requirements that aren’t being met and evaluate the associated risk to the business. (Feedback to step 4 as needed).
Putting Compliance Management Software into Action
An automated, integrated approach – through environmental compliance software, HSE compliance software, or enterprise EHS software – would allow you to set up seamless workflows between each step, track all information in one web-based database that can be used across functions, and give you the reporting and analysis tools to easily and effectively evaluate and assess progress.
Compliance management is a central SMS/EMS component that can be effectively performed with integrated, automated data management tools. Bear in mind however, that in the management systems approach, compliance management does not exist in a vacuum. It is part of a whole program that, when properly implemented, can lead you down the road of improved EHS performance.
If you have determined that your current data management tools fall short, consider evaluating new solutions. Most companies either consider building their own database in-house or decide to purchase one off-the-shelf. Either way, it is important to ensure that your solution is scalable and allows you to manage not just compliance management, but all your EHS programs in a holistic, integrated fashion.
With all of this in mind, you’ll likely find that it is more efficient and cost and resource effective to consider the off-the-shelf applications that are already built to address these requirements.