Throughout the process of trying to deal with these challenges, I ended up making just about all of the mistakes that a company can make while trying to deal with EHS compliance. I later learned that many, if not all of these mistakes, are very common with small, and even larger companies, while trying to manage EHS compliance.
Here is a summary of my mistakes:
If you’re interested to learn more about these mistakes and why these strategies don’t work, then read on…
During the early stages of all 3 companies, I made the mistake of trying to dual task my operations & HR managers with EHS compliance. This strategy never worked, for 2 very simple reasons: 1) Just like me, my managers had no real understanding of, or experience managing these regulations and 2) even if they did, they never had time to get around to dealing with it due to their primary responsibilities with the companies. Throughout the years since, I’ve seen this mistake made over and over again with companies who we’ve worked with.
I’ll never forget when I got the call from our WC provider, telling me that they wanted to setup a meeting with 2 of their “loss control” agents to learn more about our company and discuss how they could help my wind company manage safety. At the time, I was very hopeful that this was the answer to all of my OSHA compliance problems and looked forward to the meeting.
Here’s a quick summary of how that meeting went:
The 2 agents showed up at our office and began asking general questions about the company and our operations. I did my best to answer their questions, but quickly suggested that the best way for them to learn about our operations, was to go out and visit our teams in the field while they worked. They assured me that this wasn’t necessary, nor did they have the time. This was my first hint that they weren’t going to be part of my solution. Instead, they pulled out their laptop computers and directed me to their online safety resources page, which was free since I was a policy holder. They gave me a quick tour of the generic templates and training videos, and within an hour the entire meeting was over.
I’ll never forget how at the time, I actually believed that the online safety resources might be the answer to my problems. That meeting ended up being the first and last time I logged onto their resources website, and the last time I ever heard from the loss control agents. What a major disappointment!
Given the fact that our wind energy and oilfield service employees were scattered all over Texas and the country, we were forced to buy and utilize generic online safety training resources.
Why this doesn’t work:
Another related mistake I made, and routinely see, was delivering training by having employees read our procedures on their own, and then sign off on the document. This “training” method violates OSHA standards the same way as using generic content.
OSHA has a very clear requirement that employers conduct routine inspections to identify, and then correct health and safety hazards that exist in their workplace. Truth be told, we rarely conducted workplace safety inspections and it was for the same reasons that most companies fail to do it:
This probably sounds counter intuitive, but hiring EHS managers, and assuming that everything was being taken of, actually turned out to be yet another mistake I made while trying to manage compliance. I’ve written extensively about this issue in the past, but here’s a quick summary of why this strategy didn’t work for me, and why it often fails for other small companies:
In other words, it’s very difficult to find that well-rounded EHS professional who can effectively and consistently manage all aspects of compliance.
In summary, I often found out after the fact that my EHS managers simply weren’t doing their jobs and therefore put my employees and companies at serious risk. In one situation, my wind business was inspected and fined by OSHA, and in another, I discovered that one of our trucks was seriously out of DOT compliance. Had my EHS managers been doing their jobs, both of these failures would have easily been avoided. There were many more failures, but these were two of the worst instances.
I later discovered that just about all small companies make one or more of the same mistakes I made when trying to manage EHS compliance.
These mistakes often lead to a false sense of security where the company and management believe that they’re in compliance, when in reality they’re not, which can end up leading to major risks and liabilities.
I took stock of my mistakes made and lessons learned & used them to help build a new EHS consulting company with a singular mission which is to help small companies manage OSHA, EPA, TCEQ & other state environmental regulations and related risk.