A company is preparing to implement a new occupational health & safety (OHS) policy. Management has proactively gathered necessary input from interested and affected stakeholders across the organization. They have informed and trained employees on the specifics and importance of adhering to this new OHS policy and advised them of their roles and responsibilities. Now the policy must stand on its own and become incorporated into the company’s day-to-day operations. Does management just walk away – assuming that employees will implement the new policy effectively, expediently and as intended; and that no issues, and hence, risk will arise? Or are they proactive in the implementation of the program?

Plan-Do-Check-Act

The Plan-Do-Check-Act (PDCA) Model is a management method used for the control and continuous improvement of processes. It can be defined within occupational health & safety as:

“The PDCA concept is an iterative process used by an organization to achieve continual improvement. It can be applied to a management system and to each of its individual elements, as follows:

a) Plan: determine and assess occupational, health & safety risks, OHS opportunities and other risk and other opportunities; establish OHS objectives and processes necessary to deliver OHS results.

b) Do: implement the processes planned.

c) Check: monitor and measure activities and processes with regard to the organization’s OHS policy and OHS objectives; and report the results.

d) Act: Take actions to continually improve the OHS performance to achieve the intended outcomes.” ¹

¹ ISO 45001:2018(E)

In the scenario above, the first two phases (Plan, Do) of the full PDCA cycle have been completed. The next critical step is to Check. The company needs to check and make certain the new OHS policy is effective. Is it functioning properly and delivering intended results? How implementation is proceeding must be constantly assessed and monitored – frequently accomplished by internal auditing.

Putting the “Check” in PDCA – Internal Auditing

In our scenario, internal auditing allows the company to evaluate how implementation of the policy is proceeding. As the name suggests, the audit function is performed by employees within the organization itself (as opposed to external auditing); and when performed on an ongoing basis, it allows for quick action (the “A” in the PDCA cycle) should barriers or issues arise. When carefully designed and effectively communicated, planned OHS policies and programs can be successful when they first “hit the ground”; however        implementation in the real world is rarely 100% effective even in the most sophisticated of organizations. A well-designed internal audit process can help an organization learn how it is truly operating – identifying inherent barriers that can limit effective OHS policy implementation and risk control. Internal auditing enables the company to take action.

Internal auditing can take many forms. It can be a formal process – such as documented and regimented  routine inspections or simple checklists. Or it can be a more informal process with regard to OHS program implementation – such as safety walks (where, for example, senior management joins the OHS professional on the plant floor with the express purpose of interacting with employees with a focus on safety). The size and complexity of the organization – as well as what OHS policy or program is being implemented – are factors in determining which is more effective. For example, implementing a program that requires employees to confirm that fire extinguishers are visible, unobstructed, and in designated locations; verify that the locking pin is intact and the tamper seal is unbroken; and confirm the pressure gauge or indicator is in the operable range/position may best be accomplished by a simple checklist and/or placed within a larger OHS checklist or audit scheme.

In the context of a more complex and varied OHS policy or program, identifying possible implementation barriers ahead of time (or proactively auditing to identify what barriers may be present) may very well be the most effective way to prepare for OHS policy or program implementation. This will allow for more valuable measuring and monitoring of those identified barriers – better enabling quick and nimble action when and where warranted.

In Conclusion

It is simply not enough to carefully plan and introduce a new OHS policy – or any policy for that matter – without checking to assure that the policy has taken (or will take) root and become ingrained into day-to-day operations. Without some sort of internal audit mechanism, a company likely will not be aware of any issues or roadblocks that present themselves – preventing effective implementation and risk reduction.

HETI…Here to Help

The environmental health & safety (EHS) professionals at HETI can provide guidance and valuable technical support on the implementation and continuous improvement of OHS programs and policies. Whether it’s helping establish a new ISO-conforming OHS Management System…or performing a gap assessment on a mature one…HETI is available to support those efforts.

 For further information about HETI’s EHS services, please contact us.