What should be the focus of a fully developed Health, Safety, Security and Environmental Safety Management System/Program?
First it should be focussed on the management role of oversight, providing sufficient information for management review to establish that all processes are functioning as intended and to allow for identification of issues so that a realignment of resources can be made as a part of the continuous improvement process. One key area to ensure is part of this process, is the tracking of system improvement action items/follow-ups from internal and external audits, management reviews and other activities .
In the last decade there has been a push to add many formerly recommended management areas as required components of management systems with the latest being the recommended adoption of the I2P2 (Injury and Illness Prevention Processes) as a set of requirements for safety management. Ergonomics may finally get the nod as well. The implementation of System Safety under ISO 31000 for risk assessment is also seeing increased focus as of late. All of these processes fall under a general Safety Management Program.
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Protecting the health of employees is a key activity of such programs as outlined by OSHA. Areas to be covered include but are not limited to
- Access to medical records
- Hearing protection program
- Exposure monitoring and notification
- X-ray monitoring program
- Chemical Hazard communication
- Lab Standard
- Fume hood and ventilation program
- Task & hazard risk assessment process
- Personnel Protection task assessments establishing Need and use of PPE
- Establishment of a documented Chemical Hygiene Management Plan
- Additional focus areas as out lined in 29 CFR 1910 subpart Z
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The safety management program will encompass the industrial hygiene environmental, and security areas under one overall program. The following specific areas should be covered.
- Establish Management oversite, roles, and responsibilities
- Comprehensive Risk management and assessment process
- System for managing documentaton. (managment systems, procedures, facility CAD/CAM drawing, equipment procedures, manuals, etc)
- Personnel selection, training, and development.
- Project management and review
- Prestart-up Safety Reviews
- Security evaluation and implementation process
- Management of Change
- Operations & maintenance Activities
- Procedures documentation and up-keep
- Maintenance and Inspection of safety critical items
- Regulatory compliance
- Management of Contractors
- Incident reporting, investigation, documentation & analysis
- Emergency planning
- Management systems action item and follow-up tracking and Stewardship
- Management system assessment and continuous improvement process.
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The EPA outlines specific requirements that need to be in place.
- Environmental Plan
- Hazardous waste management program
- Required permit management & communications (air & water)
- Environmental Aspects & Environmental Business Plan documented
- Spill Prevention Control and Countermeasures Plan
- Process Safety Management is required as of 1997 and covers 14 areas as outline in 29 CFR 1910.119
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Security
Security around Specific processes and shipping of materials has seen increased focus in the last decade.
- general security
- site access
- screening
- Homeland security requirements
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