EHS policy review procedure recommendations

How many times have you walked into a company and found they haven’t reviewed their policies or maintained some documentation in the last year…or five? Establishing a clear policy review procedure can prevent this issue. But why do so many EHS professionals not review and update their programs? Determine which policies need to be updated, and when?

The issue with generic policies

I used to work for a company that had all cookie-cutter policies purchased from a generic online source. Many of you probably know which one. The only thing they had to do was replace “[Company Name]” with their company’s name and put it into place.

I began a review of the EHS policies and programs—only to find out there were many issues. Someone had entered the wrong regulatory information in these generic documents.

And what’s worse—no one had caught these mistakes in the past 10 years. Yes, they actually went 10 whole years with the wrong information in their policies. They were incorrectly teaching this to their employees.

Without getting into all the risks associated with the cookie-cutter approach, there are more problems that lie with these generic program documents. Therefore, a policy review procedure should be implemented. This will help adjust these documents for accuracy.

First, they’re not specific to your company or processes.

Second, does the EHS professional even know what these documents say? Are they going to spend any amount of time going through each one to read or update it? Probably not, since time is one thing we don’t have enough of in our profession.

How often to complete a policy review

Regardless of the type of program you have at your company, you need to update your policy documents regularly. Consider how frequently and which ones to update.

Well, that depends on the program. I’ll start off by saying you should, at minimum, review all of your policies annually. You need to ensure the process and/or regulations for that program haven’t changed in the past year. Use a comprehensive policy review procedure.

Management of change for policy documents

My best advice to anyone in this field is to establish a really good management of change (MOC) policy. Upper management must support this process because it may otherwise become neglected.

[You can read our full explanation of the MOC process here.]

Any time something in your facility or company changes, you must fill out the MOC paperwork and send it to the designated area managers for approval. This allows you to see if there’s something you need to review in your programs or if you can wait for the annual review. In the meantime, ensure the policy review procedure is followed.

I personally feel as though many companies fail to actually review the policies and just pencil whip the process. The policy review procedure takes a lot of time to perform properly, and many of us don’t have much extra time in our daily work lives. And many companies don’t invest in hiring an EHS intern to assist in this process either.

You may consider breaking up the review process over the entire year to complete it thoroughly. If you wait to do this all at one time, you’ll become overwhelmed. Likely, you won’t complete it as thoroughly as you could have.

If you’re the only one at your company or site who’s working on the policy review, you may not be able to complete it. You still may need to enlist the help of others. Ask your safety committee members, supervision, management, or other subject matter experts for help.

It’s up to you how you want to go about the policy review procedure. But I can tell you from personal experience that best practice is to review your policies and programs semi-annually. However, you should at least do them once a year—unless you specifically need to review a program based on your MOC’s.