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? Why do so many EHS professionals not review and update their programs? 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 that there were so many issues where someone had entered the wrong regulatory information in these generic.
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, and 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.
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 on a regular basis. How frequently, and which ones?
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 make sure that the process and/or regulations for that program haven’t changed in the past year.
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 also see if there’s something you need to review in your programs or if you can wait for the annual review.
I personally feel as though many companies fail to actually review the policies and just pencil whip the review 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 in order to thoroughly complete it. If you wait to do this all at one time, you’ll become overwhelmed and likely not 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 to 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 the best practice is to review your policies and programs on a semi-annual basis. However, you should at least do them once a year—unless you specifically need to review a program based on your MOC’s.
Jason is the EHS manager for a large global HVAC company. He has over 12 years of EHS experience in the areas of commercial construction, oil and gas, and manufacturing. He currently sits on the Advisory Board of a Division 1 university for its Environmental Sciences Graduate Program.