ES&H Audit Tips

The end of the year is here and many organizations are scheduling their "walk around" audits. Whether your focus is environmental or safety, or a combination of the two, this inspection is a part of your environmental, safety, and health (ES&H) program. The "walk around" audit is a visual approach to determine if the organization's policies and procedures are being properly implemented, verify the company is in compliance with ES&H laws, and identify what improvements or areas of concern need attention.

Before you begin your audit, here are a few tips to consider so that you can get the most of your "walk around" audit:

• Know the goals and objectives of your audit. Review your ES&H program to determine the policy and procedure for performing the audit and evaluate what standard for auditing you are using. Knowing what regulations apply to your organization with access to those regulations is a minimum, but your organization may have recommended goals that are more stringent than the regulatory guidelines. Standards such as ISO, ASTM, and NIOSH are recommendations that your organization may have incorporated into their program. Your organization might also have Best Practices to help build and reinforce your ES&H culture.
• Communicate with your safety team. Having your auditing team on board with your vision for this audit is extremely important. Clearly define the goals and objectives for the team and make sure everyone on your team knows what they will be responsible for, what procedures they are to follow, and how much time they have to complete the audit and reporting of results.
• Keep your scope, budget, and deadline reasonable. You want to have a team large enough, capable, and available to complete the audit in a timely manner, besides making the audit a reasonable task for the size of the organization. If you are considering that the audit be done internally, be aware that members of your team may not be able to provide the audit full attention during the entire project without fulfilling other project requirements.
• Follow a checklist. Since there are various standards for performing an audit, select a checklist that meets your program requirements. If your organization does not have a checklist, you may want to create one of your own. A good checklist should be designed to reflect the standard for the operation, area, and/or equipment that is being checked. Having your checklist arranged by division, department, or area may help avoid going back and forth to check equipment in an area you already went through.
• Recognize there are risks. By managing and controlling the "walk around" audit based on the organization's policies and procedures, you can give your thoughtful attention toward the audit and maintain its scope. But be aware that risks exist when you identify or fail to identify ES&H concerns, increasing the potential for financial and legal liabilities. Be careful what recommendations you make for correcting concerns, how you word findings, and who you discuss your findings and recommendations with, as some of these may be confidential or involve trade secrets. Inaccuracies can be avoided by having meetings with your team before beginning the walk through and after completing the audit, then by cross checking your information. When looking at recommendations, be realistic about what your organization will be willing to budget in an acceptable time frame.
• Get employees involved. They know that this is coming and there should be a certain part of preparedness within each plant, department, etc. since the walk around is a regular occurrence. You want cooperation and to make this as useful for everyone as possible. Arrange to meet with a representative from each plant or area to go through the walk with them. This way you can provide comments directly. Talk to employees where you can. They are the ones who know the operations, tools, and equipment. And they can usually offer suggestions on how to correct an ES&H concern. In many situations, problems can be fixed on the spot or as soon as possible when the employee in that work station is present.
• Review your audit policies and procedures. When your audit is complete, make recommendations where appropriate on what you could have done differently with your "walk around". Evaluate your scope, budget, and deadline to verify it was appropriate in meeting the program requirements. There could be something outdated with the policies or missing in the procedures you are using to perform the "walk around". For example, you may have the same people year after year looking at the same things. Having a fresh set of eyes perform the audit annually can help bring in a different perspective.

A good "walk around" audit can be used to lay out your goals and objectives for the new year. Keep in mind that your controls may be suitable for complying with today's regulations, but may not meet future changes in the regulations. In some cases, external audits can be more advantageous than internal audits because they can provide a fresh pair of eyes, be objective, relieve some of the liability, among other things.

Battle Unexpected Absenteeism...And Win! — legalworkplace.com

Battle Unexpected Absenteeism...And Win! — legalworkplace.com

Reducing absenteeism and tardiness starts long before the employee calls out unexpectedly, it starts during the hiring when the expectations are communicated, in the written policies and procedures, and in the actions of all employees. Things recommended: reward good attendance, make the workplace a place employees want to come to work, be concerned about an employee when he or she is absent, be flexible when possible, and allow unused time to be carried over.

Performing Phase I and Phase II Environmental Site Assessments

Is it not incredible how quickly this year is moving along? Towards the end of the year we see many commercial properties changing ownership and an increase in Phase I and Phase II Environmental Site Assessments. The Phase I investigation includes a visual property inspection and review of historical property records, regulatory records, interviews with persons knowlegable about the property and surrounding area, as well as other reviews to help determine if there are any recognized environmental concerns, called RECs. When an REC becomes know, the Phase II investigation may be necessary to evaluate subsurface conditions in the soil and groundwater.

At times, the Phase I and Phase II Environmental Site Assessments may be performed simultaneously. This combination is beneficial when time is of the essence. For example, if you know the loan requirement for refinancing a dry cleaning facility requires a Phase I, it is highly likely that a Phase II will also be necessary if the dry cleaning activities were performed onsite. The chemicals used in dry cleaning activities create a REC because of their hazardous nature. Instead of waiting for the Phase I report to be complete, a Phase II subsurface investigation can be added into the scope of work to determine if a release of chemicals has occurred, thus allowing the question of whether further action will be necessary to decide on the loan.

By combining the work of both surficial and subsurface investigations, there could also be a cost savings on the project. Let us take the scenario above with the dry cleaner. By adding the Phase II scope of work, the project management time for setting up and scheduling the project can often be done at the same time. Mobilization to the site can be decreased into one mobilization depending on the location of the site. In other words, sometimes a two day consecutive site visit is less expensive with a per diem compared to the cost of driving back and forth. And the reporting can be combined into one document.

One of the disadvantages of combining a Phase I and Phase II Environmental Site Assessment together include not knowing all the RECs. If you mobilize a drilling rig to install temporary borings, you probably have a plan to collect soil and groundwater samples for dry cleaning chemicals. Immediately prior to the field implementation, you determine during the regulatory review that the property once had a retail paint shop onsite. In this case, it is relatively easy to add in the additional analysis, if needed, since both dry cleaning solvents and paint are volatile organic compounds. But there are circumstances, such as the addition of 8 RCRA metals or other chemical analysis, or increased drilling that may be needed if more RECs become known. Depending on the age of the paint shop, Lead may be an additional analysis. Other scenarios may be the location of offsite RECs that may warrant drilling for subsurface sampling in a different location on the property.

In today's economy, financial institutions are making loans but the circumstances for approving a loan have become harder. If there are RECs, there are the potential for releases from past onsite operations. Until it is clear that the property has not been impacted by chemicals from past operations, most loans will not be approved. And as long as there is the existence of contaminants beneath the subsurface, many loan officers today will not approve a loan until the regulatory agencies provide a No Further Action Required. Even then, a clean bill of health on the property via remediation may be required by the loan. It is important to understand the process by talking to your financial officer or environmental consultant before, during, and after the assessment is performed.

Audit Fatigue - Perhaps you need a fresh approach

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Auditing can become mundane, especially when done by the same person or group of people every year, year after year. Your procedure and timing may be too predictable and you expect the same results. Perhaps it is time for a change in pace. Try doing your audit more spontaneous and with a different person or group. If you hire an outside source for your audits, check with them to see how they are changing their process or approach. At a minimum, there should be new safety rules and regulations that apply from the last audit.

The auditor can interview different people and change the questions. Sending out a survey in advance can provide the people being interviewed with time to think about the questions and write out comments. But it can also be important to plan surveys by reviewing the records available and incorporating some key points and statistics into the surveys. It shouldn't surprise you to find out people don't always know the happenings outside their own work area. A simple question about if they knew something that happened in the company from a different division or department will help you to know very quickly if there is some communication barriers.

If you think you are not considering the human factors, such as stress, trust, teamwork and leadership, why not phase your questions towards these factors? Or maybe try performing the interview portions of the audit as a group meeting. Brainstorming about safety in the workplace can be beneficial when a group discusses the issues. Getting people involved more with the process helps to create buy-in and accountability.

All too often the audit is looked at as a snapshot in time, while the goal for safety is longterm. Sharing the audit information and follow-up are ways to keep safety in the minds of everyone. In order to build the perception that the workplace is safe, there needs to not only be support in leadership but thinking about safety needs to be a continual behavior that involves all levels of the company.

Noise in Workplace related to Heart Problems

http://www.ishn.com/Articles/Industry_News/BNP_GUID_9-5-2006_A_10000000000000920175

This article about persistent, loud noise in the workplace being related to increased heart disease just makes common sense. How many times have we all experienced overhearing people arguing, kids screaming, or tools such as hammering that have distracted us and caused headaches? We become more anxious and irritable - stressed. We want to escape and go for a walk or find a quiet place to relax. Destressing from work may be trying to relax on the drive home. If we are driving along a noisy highway, we close the windows and turn on music to adjust the noise around us, making a more appealing listening environment.

Constant, loud noise can put a strain on your mental state that should be minimized at the source. There are numerous engineering controls to help decrease noise on machines or sound barriers to minimize noise in specific areas. However, engineering controls are only part of the correction. In some circumstances, the addition of PPE is needed. It is important to recognize that PPE can add something to that worker's quality of life. Convincing a worker who has been doing his job without PPE everyday for years may be necessary and for his best interest. If he has become content with the way he does his job because that is the way he has always done it, we may need to persuade him that there are always ways to improve what we are doing. Comfort and appearance should no longer be an issue as PPE has improved over the years and is more comfortable to wear and more aesthetic. And getting the employee involved with PPE selection may be advantageous in purchasing something they will use.

GAEPD USTMP New Report Templates

http://www.georgiaepd.com/Documents/epdforms_lpb.html#ust


The GAEPD Underground Storage Tank Management Program has provided new reporting templates for the Monitoring Only (MO) and Remediation Reports. These are available online. The new templates are very similar to the prior Progress Report templates from 2001, with the addition for remediation. The GAEPD has indicated that the MO template can be used if there is only one mobile vacuum event performed onsite, but if more than one event is performed then the remediation template would be necessary. Chemical remediation also requires using the remediation template, although this template appears to be best setup for discussing operation and maintenance (O&M) and remediation results on a full scale system. Only time will tell how user friendly these new forms will be. The main thing for now is getting everyone onboard with consistency of reporting.

NSC: OSHA, MSHA, NIOSH Leaders Discuss the State of Occupational Safety | EHS Today

NSC: OSHA, MSHA, NIOSH Leaders Discuss the State of Occupational Safety EHS Today

In an October 5 National Safety Council Conference, Keynote Speakers included OSHA Administrator David Michaels, NIOSH Director John Howard, and MSHA Administrator Joe Main. I2P2, Vaccination, and Black Lung are on the regulators minds these days. In his keynote speech, David Michaels indicated that OSHA cannot be everywhere at once so the agency "must think of creative ways to have a bigger impact. The key to workplace safety and health is working on prevention". Indead, one key to prevention is communication. For example, the Illness and Injury Prevention Program, called I2P2, proposes finding and fixing safety problems before they cause occurrences. To do this there must be a plan of action that is endorsed by those in charge and implemented by everyone from human resources, management, and employees. Getting key imput from those directly affected and getting support from those above is critical in making realistic safety goals, purchasing appropriate engineering controls and PPE, properly using these controls and equipment, etc. Finding and fixing by means of proper and thorough communication are challenges every company faces.

On a different note, John Howard spoke on vaccination and the timing of flu season on Oct 1. As companies continue to struggle with meeting production goals for the end of 2010, sick time runs out on some employees, stress of missing days when sick to only have to pick up the pace when one returns back to work cause other employees to come to work sick, while in other circumstance employees sometime miss work to care for their sick children. Besides vaccination, when was the last time your keyboard, mouse, and phone were cleaned? And, keeping a small hand sanitizer around is another way to minimize germs.

Joe Main's emphasis was also on prevention, that of keeping miners safe through re-education programs, improvements on dust respirators and engineering controls, and better evaluations of the mining situations during shift changes. Again, communication challenges must be overcome to plan, find and fix problems to minimize other incidents in the future.