Are You Compliant? Maybe Not
When I ask "are you compliant" I'm not talking just about regulations. I am also asking if your company generally follows all of its own internal policies, programs and procedures. When I say maybe not, some of you may find that hard to swallow. So, here is another question for you. Have you checked? You may think you are compliant, but how do you really know? I submit to you that you aren't truly compliant with something until you know what is required in the first place.
Pick A Program, Any Program!
A good place to start is to pick a single company EHS policy, program or procedure and plan a mock demonstration to be performed in the field. You'll need your EHS person for sure. But you should get your facility manager, supervisors, and the people expected to perform the tasks under the chosen document as well. The reason you need management and supervision is that it's hard to truly grasp where your gaps are until you see them played out.
You will have the typical employees who need to do the work do the contents of the procedure. One thing that will be very telling is if they do the work from memory or get (or ask for) the document in question. The people performing the task should understand that they aren't being asked to memorize the document. They are being asked to properly demonstrate, minus actually going into dangerous areas, the requirements called for in the document.
It's pretty hard to argue with the document itself in terms of what it calls for. However, there may be portions of it that are not quite clear. Worse yet, the document may call for things the facility just doesn't have the ability to do. This should be caught in facility and corporate reviews. But for that to happen, you actually have to look at the document. Once you try things out in the field, it should become pretty clear where many issues are. If the employees perform all tasks, including getting the needed equipment and calling for the applicable parties, you've got things down. If they miss a lot of steps, and these are some of your more dependable workers, now management sees it's issues.
But Corporate Said...
It's been in my experience that production and operations level employees sometimes use what corporate says as the "law" of EHS matters. Often times, corporate staff know their stuff. But, they are humans and can be in error from time to time. Furthermore, they may not actually have said the wrong thing, but the facility missed some key items that were said in terms of executing what was communicated.
This misinterpretation, miscommunication, or misunderstanding of EHS matters can cause quite a lot of problems for facilities despite everyone's best intentions. It also means that you may not actually be in compliance with something if you didn't look at the source document yourself. You know a good way to help stop that? If there is a policy, program, or procedure concerning an EHS issue, get it and examine it. The things corporate say should be verifiable in the official documents. If they say things outside of that, they should be communicated to facilities as either cited regulatory requirements ore recommendations.
The culture at a company should be such that facilities are not afraid to bring up concerns or challenge things legitimately. If a member of corporate says something is a certain way, but that clearly is at odds with what the approved document says, bring that up. Be respectful of course. But do bring this up. It's perfectly reasonable to say, well this document tells me to do such and such. If it is wrong, I request you put it through the process of being revised. The less facilities rely on unsubstantiated verbal communication, the less likely the facilities will find themselves out of compliance internally or externally. At the end of the day, many if not most of the risks associated with EHS are at the facility level. So, they need to be vigilant in knowing what is required before resting on their laurels.