Building a successful EHS program

To build something, you first need a foundation. The foundation of a successful environmental, health, and safety (EHS) program involves creating, reviewing, and updating all of the required programs, plans, and procedures that OSHA requires. Once that foundation is established, employers can expand into best practices that go beyond the regulations and more effectively protect workers.

Getting started requires knowing all the requirements that apply to your operations. Despite a common misconception, OSHA does not list requirements by industry or business type such as retail or manufacturing. Rather, employers must determine which requirements apply based on their operations and workers’ exposures.

Where to start?

With so many different OSHA regulations, employers can easily overlook some requirements. Even if you don’t know that a particular standard applies to your business, OSHA can still cite for non-compliance.

Some requirements apply to nearly any type of business. These might include:

• Developing an emergency action plan,
• Maintaining exit routes,
• Inspecting walking-working surfaces,
• Training on using or handling chemicals (even custodial staff using cleaning chemicals), and
• Training to handle or stack boxes or other materials.

For most other regulations, employers must evaluate operations to determine which requirements apply. Employers may need to train forklift operators, provide personal protective equipment, ensure proper machine guarding, develop lockout/tagout procedures, or provide training on bloodborne pathogens.

Beyond the basics

Even when an OSHA regulation does not specifically require a written plan or employee training, documenting procedures and training workers on them is a best practice — and even if not written in the regulations, written plans or training may be necessary to avoid an OSHA citation for unsafe conditions or behaviors.

For example, OSHA’s regulation on material handling doesn’t specifically require employee training. However, if workers stack materials haphazardly or block exit routes, OSHA can issue citations — and those violations could cause worker injuries or deaths.

Environmental requirements

In addition to OSHA requirements, EHS professionals often have to handle some environmental regulations, like underground storage tanks, aboveground storage tanks, hazardous waste, and universal waste. Although federal EPA has standards for these topics, it’s critical for employers to check their state and local regulations. EPA often delegates its authority to state environmental agencies. To get that authority, states must have a program that is as stringent as the federal program, and they may choose to be even stricter.

It’s been said that expertise is really just a mastery of the basics. Once an employer has the basic foundation down, it can continue to build upon that foundation to create excellence.