5 Types of Changes That Can Increase EHS Risks
Just like the objectives of EHS management, EHS risks are also diverse. But many EHS risks have one thing in common: They are the result of some type of change, which can be expected or unexpected. If you want to mitigate successfully EHS risks, you need to have a grasp of the changes that can affect your organization. In this post, we provide a summary of the types of changes to look for, and that can create or increase EHS risks.
Changes in People
Employees constantly change. If a company grows, it hires new people. Also, existing employees leave or retire and are replaced by new employees. Changes in people give rise to a number of EHS risks. First, since new employees are not familiar yet with work processes, there is an increased risk of workplace incidents. Second, if experienced employees leave or retire, there is a risk of a loss of knowledge that can lead to safety risks and compliance risks if the retiring employees were responsible for compliance tasks and were familiar with industry best practices. To mitigate risks that can be the result of changes in people, be sure to provide proper training to all new employees, and to have a system in place to retain knowledge of existing employees.
Changes in Processes
Even if there has been no employee turnover for a long time, and all employees are highly skilled and trained, a change in a work process can be enough to increase risks that lead to incidents or undermine operational excellence. A process change can be the result of a number of elements: new equipment, changes in workflows, and new control measures to reduce hazards (elimination, substitution, engineering controls, administrative controls, etc.). Any change in process means that people perform some of their tasks differently, thus increasing risks. To mitigate risks that can be the result of changes in processes, be sure to document the process change, provide proper training to employees on the revised process, and implement a Management of Change (MoC) software solution to effectively register, track and manage all change requests.
Changes in Products
If the product you sell changes because of new parts, new components, new chemical ingredients or a different chemical composition, there could be a wide range of new risks. First, compliance risks could surface if the new products or parts are not compliant with chemical or product regulations (e.g. REACH, Conflict Minerals, etc.). Second, there could be reputational risks if, because of a change, a product may be less safe to workers and consumers, and more harmful to the environment. To mitigate risks that can be the result of product changes, be sure to assess the impacts of the changes by determining the applicability of product and chemical regulations. In addition, re-evaluate the environmental, health and safety impacts of the product to see if there are changes that could result in new or increased reputational risks.
Changes in Regulations
The regulatory landscape changes all the time, either through new regulations or updates to existing regulations. Companies in heavily regulated industries, and especially those who have a presence in multiple geographies, are strongly impacted by changes in environmental and occupational safety and health regulations. This can increase the risks of non-compliance, especially since, unlike other types of changes over which a company has some control, regulatory changes are beyond any company’s control. Regulatory changes can hit unexpectedly and have serious consequences. To mitigate risks that can be the result of changes in regulations, be sure to have a regulatory monitoring system in place where changes in regulations are brought to the attention of the organization, and the impacts of regulatory changes on people, processes and products are evaluated.
Changes in Third-Parties
Companies are part of ecosystems that include suppliers, partners, contractors and subcontractors, and others. Any change in a third-party may increase EHS risks. For example, if you change subcontractors, and you’re not entirely aware of their safety performance, they could affect your own safety performance. Also, if you have been outsourcing your environmental remediation efforts to another firm for years with satisfactory results, and suddenly you need to find another firm, your environmental performance may suffer if you do not select the right firm. To mitigate risks that can be the result of changes in third-parties, be sure to clearly identify the potential EHS risks that can emanate from third-parties, engage with third-parties on an on-going basis to establish full transparency (not just one-time annual audits or questionnaires), and rigorously assess and qualify any new third-party.
When you have a good understanding of all types of changes that can affect your organization, and the impact of each change on EHS risks, you enhance EHS performance and ensure operational resilience. Software solutions for EHS management and Risk management can help you identify, evaluate and mitigate all EHS risks arising from changes affecting the enterprise.