Creating Your Environmental, Health and Safety Policy

It is essential for top management of the company to define the company’s environmental, health and safety (“EH&S”) policy in a manner that is appropriate to the nature, scale and environmental impacts of the company’s operational activities.  Among other things, the policy should include a commitment to continual improvement and prevention of pollution and creating and maintaining a safe and healthy workplaces and facilities for employees and customers; a commitment to comply with applicable legal and other requirements to which the company subscribes and which relate to its EH&S aspects; and a framework for setting and reviewing EH&S objectives and targets.  The policy should include an explicit commitment by the company to promote a safe and healthy environment for employees, contractors, agents, customers and other visitors to the company’s facilities; to comply with state and federal laws and regulations relating to workplace and environmental health and safety; to operate an EH&S management system aligned with the requirements of a recognized standard that ensures continuous improvement through risk assessment, risk minimization and performance reporting; and assuring that managers and employees are trained and accountable for preventing work related injuries and illness and that appropriate wellness programs are available to contribute to the productivity, health and well-being of employees.  The policy should include a list of the steps that the company intends to take in order to further its stated EH&S goals and objectives such as creating safety committees, which are discussed below; promulgation and enforcement of work rules to promote best environmental health and safety practices; compliance with laws, regulations, policies, and the company’s own EH&S procedures and rules; and supporting an EH&S culture throughout the organization.  The policy should be documented, implemented and maintained; communicated to all persons working for or on behalf of the company; readily available to the public; and subject to periodic review to ensure that it remains relevant and appropriate to the company.
One useful illustration of an EH&S policy began with a simple statement that the organization embraced EH&S objectives as core business values and that providing a safe and healthy workplace for employees and caring for and protecting the environment and the communities in which the organization operated were fundamental beliefs of the organization.  The policy went on to assert that the organization was committed to developing and implementing management systems that protected the environment and safeguarded the health of employees while allowing the organization to provide for employee livelihood, customer needs and shareholder returns.  The policy then listed specific commitments including the following:

• Demonstrating visible and active leadership in all of the organization’s business activities by providing resources necessary to manage and communicate EH&S commitment, expectations, and accountability in the same manner as any other critical business function
• Establishing and enforcing appropriate systems and procedures to ensure compliance with the policy and the principles described in the policy
• Educating employees on safe work behaviors
• Implementing proactive hazard identification and following through with elimination and control of identified hazards
• Implementing and auditing continuous EH&S improvement processes
• Promoting a positive “Safety Culture” lifestyle both on and off the job
• Complying with applicable laws, regulations, and statutory obligations
• Ensuring open lines of communication to employees, subcontractors, and visitors to our work sites regarding the organization’s workplace health and safety arrangements
• Developing processes that facilitate continual improvement in the health and safety management system and the organization’s health and safety performance
• Including measurable EH&S targets in the organization’s business plans so that everyone who performs work for the organization is responsible and held accountable to help achieve these targets

his article is adapted from material in Sustainability and Corporate Governance: A Handbook for Sustainable Entrepreneurs, which is prepared and distributed by the Sustainable Entrepreneurship Project and can be downloaded here.  The Project website also has examples of EH&S policies that can be used as tools for drafting such a policy for your company.
Alan Gutterman is the Founding Director of the Sustainable Entrepreneurship Project, which engages in and promotes research, education and training activities relating to entrepreneurial ventures launched with the aspiration to create sustainable enterprises that achieve significant growth in scale and value creation through the development of innovative products or services which form the basis for a successful international business.  Visit the Project’s Library of Resources for Sustainable Entrepreneurs to download handbooks, guides, articles and other materials relating to sustainable entrepreneurship and keep up with the Project’s activities by following Alan on LinkedIn, Twitter and Facebook.