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Production Needs A Voice In EHS Changes

Updated: Aug 21, 2022

EHS Changes Need Direct Production Representation

If you get the various vice presidents of departments like procurement, operations, etc. together on an EHS changes (or similar) committee, that production would naturally be represented. And I'd say you'd likely be wrong in that assumption. Why is that the case some of you may be asking. Well, would you say your vice president or director of operations has the same day to day perspective as a location manager likely has? Probably not unless they've were very recently location managers (or similar) themselves.

It's for this reason that location managers and their location level EHS management need to have input on changes that will affect their location. Depending on the company, locations may be nearly identical to each other or are nearly as different as night is from day. See, whatever the task is, whether major changes in fall protection, improvements in safety guards for equipment, or training changes, much falls to the locations. The risks tend to be theirs, after all. They have to put it in place. So, they should have the ability to chime in before things are finalized and become the "law" of the company.

Do Your EHS Changes Go Something Like This?

The EHS Change Process

I recognize that each business does things differently. But that doesn't mean they aren't also very similar. That said, I'm going to make a list of the general order in which some companies may handle EHS changes. Heck, this may be how many different types of changes happen.

  1. Something bad happens at the company such as a major or catastrophic incident, that caused severe injury or property damage.

  2. The company's leadership takes notice and tasks high level management and/or the EHS department leadership with fixing the problem.

  3. The EHS department or it's equivalent in your company performs research and analysis on regulations, consensus standards (NFPA, ANSI, etc.), and how the work was done that lead to the catastrophe.

  4. EHS department comes up with a solution, typically in the form of a policy, program or procedure, and submits it to upper level company leadership for approval.

  5. Leadership may have some back and forth with the EHS department, but eventually an approved version comes of it.

  6. The policy, program, or procedure is rolled out to the individual locations to implement within a certain time frame.

  7. The facilities/locations look at the new change and attempt to put what they can in place.

Issues With The Change Process

Noticed how neither the EHS department nor upper level company leadership included the location management in the change process? That wasn't an oversight in the scenario set up. This actually happens. A major problem with this method is that the EHS changes are not weighed against what leadership expects the locations to be able to produce regardless of the approved changes.

Some EHS changes are not so easy that they can just be "stamped" as approved and passed off to the locations. Imagine being a location manager who's already resourced strapped and on a shoestring budget. Your employees are operating at a high level of work output day after day. You aren't compliant with all the EHS rules and regulations for your company and the government. However, you want everyone to go home the way they came in. You try to comply. You even look for ways to get better at that with what little you have versus the high expectations on you. And then the company EHS department tells you to make major improvements to your old electrical equipment within 6 months... I can tell you that electrical equipment generally is not cheap, though what is these days?

As a location manager, you find yourself between a rock and a hard place. The requirements you have to meet have increased overall. You don't see how you can maintain such a high level of production output and follow the new EHS requirements. To make matters worse, you may actually know that the EHS changes are approved by a group of people at the level of your boss's boss. Or, you may be completely ignorant to that.

Costs, Costs, And More Costs!

Congratulations. The company has set up a situation where the location cannot do both the levels of expected production and comply with the approved EHS changes. What is a location likely to do? Well, they will probably do what their bosses enforce. If they don't meet their numbers, and it risks their jobs, they probably will focus on their production numbers. If the safety rules are more strictly enforced, and could make people lose their jobs, they probably will do that.

If both production and EHS are enforced strongly... the company will probably start losing people fairly quickly. They may also have more accidents and injuries as the employees try to do both demands and find that they can't. This will likely lead to substantial injuries and property damage in both frequency and severity. These things have a doubly nasty effect in increasing the cost of doing business while simultaneously reducing production output. Losses all around! So, this is a real problem that needs addressing. Lets look at some ways that EHS changes can occur to minimize the potential for issues.

Tips For Improvement

I'm pretty sure you don't want the company to have it's losses increase. But you want to take EHS more seriously for exactly that reason. We've got to remember that things like safety, while very important, are there to help support production by keeping costs under control. Property damages, production output reduction, injuries, and regulatory fines are typically more costly than training, providing PPE, and maintaining equipment. Without further pomp and circumstance, let's get to the tips.

  1. Take a hard look at the production process for your locations. Review things like:

    1. Location output

    2. Location budget

    3. Location resources (specific staffing and number of employees; equipment; etc.)

    4. Location production projections (estimates of output over time based on expected sales)

  2. Have EHS department (or rough equivalent) detail their proposed solution to a given problem with the following:

    1. Description of the issue

    2. Description of the solution notating the basis for the specific parts of the solution such as:

      1. Applicable legal/regulatory requirements

      2. Company incident records

      3. Recommendations based on study of the applicable parts of the production process and/or consensus standards (ANSI, NFPA, etc.)

  3. The rough draft or outline of the solution is presented to location management representatives (location manager or a designee).

    1. It's good to have this as part of any official EHS related committees your company may have from a corporate level.

  4. Allow a comment/review period similar to how regulators like OSHA or the FAA, when proposing new rules and regulation.

    1. Comments can be submitted here for what's currently available for comment.

    2. I like the general idea and set up for being able to submit comments. Where I have more recently participated in this was with the FAA drone rule change for having remote ID.

    3. Your company should consider using technology, such as with Microsoft Office, to send forms or surveys, to location management representation.

    4. The comment period should be at least one month.

    5. The comments/feedback should reflect the locations attempting to see what would be needed to implement the proposed changes at their location. Locations should consider things like:

      1. Currently available budget

      2. Currently available resources and personnel

      3. Would additional resources be made available as part of the change?

      4. Potential interruptions or slow downs in production, both in implementing the change and in maintaining it.

  5. Locations should not consider the comment period a time to either ignore things or chime in with what amounts to "This is dumb. I don't want to do this mess."

    1. Both the EHS department and upper level management are likely to ignore these types of comments.

    2. Location management will have wasted a valuable chance to improve things with comments likely to be ignored.

  6. After the comment period, the EHS department would be tasked with addressing the valid comments.

  7. After EHS addresses the comments, modifies the solution document, makes resource allocation recommendations, and recommends enforcement recommendations, upper level management reviews.

  8. After some likely back and forth discussion between upper level management and the EHS department, some version of the solution will probably become approved.

  9. This approved solution should come with more than just approval from the company. It should represent a solution that reflects full company backing.

    1. The solution has been proven by the EHS department.

    2. The solution has been reviewed and vetted by the locations tasked with implementing it.

    3. The solution has been approved and backed by upper level management, complete with the allocation of:

      1. Needed resources and funds

      2. Understanding of any justifiable needs that may have been overlooked or were unknown

      3. A reasonable time frame to complete

      4. A commitment to enforcement


Running a business can definitely be a challenge. It's even more of one if a single person or group thinks they know all there is to know about how to run the company. An executive and a location manager are likely going to have very different perspectives on running things. One will be very higher level in their views. The other will be focused on how to make things work day to day.

With many EHS changes, they are applied to the whole company, but it's the location management tasked with implementing them for their specific location. The above tips will help ensure that the subject matter experts, location management, and high level company leadership get together to make sure solutions are a benefit and not just another problem. Environmental, health, and safety may not be the reasons why the company exists. But proper management of them can save a lot of time, money, and tragedy from happening to a company. Keep the lines of communication open, and include all relevant stakeholders in the change process BEFORE authorizing and acting on the change.

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