Creative Solutions--Not Just Problems

Practice leaving behind a process and list of actions/solutions, and not just a list of findings.

WHEN I first became an EHS manager, I thought I knew most of what I needed to know as a professional (during the years since then, I have found out just how much I didn't know), but I would, somewhat infrequently, seek help from an external consultant either to confirm my thoughts or to provide creative solutions for the "opportunities" I had identified. Unfortunately, far too many times I received confirmation of the problems, but seldom was I presented with any solutions, much less creative ones!

I decided that if I were ever a consultant, I wanted to make certain to provide solutions that solved the problem while minimizing any of the downsides (increased cost, lower efficiency, lower quality, decreased morale, etc.). Additionally, this approach works whether you are an "internal consultant" working at your own facility or another facility owned by your company, or you are an "external consultant" working for a client. While often challenging, it is much more rewarding than showing people how smart you are.

How do you go about doing this? Well, rather than taking the more typical "one size fits all" approach, try for the more business-integrated/system-oriented solution. While not all clients will be receptive, most will, and certainly the solutions provided will be more effective and of significantly more value in the longer term.

Let's take a look at some working examples.

Compliance Audits
Compliance audits provide the most fertile ground for practicing this approach. Most organizations that engage a consultant to perform compliance audits want to improve their programs. Often, the identified issues are the result of a lack of knowledge of the requirements--but more often than not, the organization has done an inadequate job of developing and implementing the programs and systems necessary to ensure compliance.

Simply recommending that the client develop the necessary "programs" often results in huge piles of paper that do not accurately reflect how things are done and, as often as not, result in no increase in EHS performance. Alternatively, leveraging your own experiences, bringing in best known practices, and focusing on practical business solutions that enable compliance are more likely to "stick," resulting in sustainable compliance for the client. Practice leaving behind a process and list of actions/solutions, and not just a list of findings.

Management System Audits
Like compliance audits, auditing of management systems is typically done for clients that want to improve their programs. For many companies, the concept of management systems is quite new, and it is very possible that weaknesses in the developed and implemented systems are due to a lack of familiarity with successful models.

Also like compliance audits, a skilled EHS consultant brings in perspectives from a variety of organizations. He or she can share what works and what doesn't work. Recognizing that management systems are not "cookie cutter" solutions, customizing the approach to the culture of the organization is absolutely critical to long term success. Again, focus on solutions, not just the findings.

Policy/Program/Process Development
When you are requested to develop or support the development of policies, programs, or processes (either compliance- or management system-related) for a client company, it is important to avoid the "sit in the office and write a program" approach.

Programs and processes must be developed with stakeholder input and involvement in order to ensure implementation. Even when driven by regulations, people feel better knowing that their peers were involved in the development process and will be much more likely to support the new or revised programs. More important, the people doing the work are often the best source of the information needed to improve the processes and to develop effective management systems that are sustainable. This is how you can improve not only EHS performance, but business performance, as well.

Many consultants spend a large amount of time training client companies, and certainly effective training is critical to the communication and education required for employees, as well as for compliance purposes. However, new technology has provided us with excellent opportunities that greatly improve the effectiveness and the flexibility of the training provided.

The use of computer-based training and other electronic media to provide training--particularly administrative, awareness, and recurrent training--minimizes the impact on operations, better meets the audience's needs, and in the long term, significantly reduces the costs related to training.

Even though highly interactive, these programs will never replace instructor-led training. But as an additional tool in your toolkit, they increase your credibility and demonstrate your commitment to the best solution available. Once again, you can provide a business-supporting solution, in this case just by sitting down!

Engineering Design
As an internal EHS consultant, this area is particularly important. Establishing yourself as part of the capital approval process and ensuring that environmental, health, and safety is "designed into" equipment, buildings, and processes is the best (and most cost-effective) way to stop problems before they start.

While OSHA's Process Safety Management Standard requires that many sites do process hazard reviews prior to building and installing certain process equipment, most industrial equipment does not undergo this valuable review. Also, just because you can buy a piece of equipment for a specific application does not mean it is appropriate for that application. Imbedding process hazard reviews and an effective management-of-change program into your practices will ensure the highest levels of protection. Finally, recognize that you and your staff may or may not have all of the requisite skills to perform this type of review; never fail to utilize external experts when they are needed.

As an external consultant, the situation is somewhat different. OSHA requires that employers establish proper hierarchies of control. The first approach considered should always be engineering controls, followed then by administrative controls, and finally, by the proper use of personal protective equipment. Consideration of these controls during design may certainly support proper implementation, but often a client does not well understand how best to meet these requirements. As a consultant, you may be asked to determine PPE requirements, perform industrial hygiene monitoring, or even design ventilation or abatement systems. Always take the opportunity to advise the client on the best approach and solution, even if it is not the one originally desired. Remember, you are the expert.

Industrial Hygiene Strategies
Many clients recognize the need to properly characterize worker exposures; however, they lack the knowledge and or the in-house capability to support the activity. Rather, they choose to outsource it. When confronting this request, keep in mind that clients probably lack a full understanding of the various approaches available to them.

Take all options into consideration and present a strategy that focuses on the relevant business issues and incorporates all types of assessments and decision-making (personal monitoring, area monitoring, area surveys, worker surveys, professional judgment, and others). Keeping the strategy focused and achievable will ensure that it is in fact implemented by the clients.

Business Issues/Flexibility
Finally, in all cases, be flexible! Remember that every client is different; in fact, every client site may be different. Each has different needs and different cultures, and because of this, the solutions required will necessarily be different.

It would, of course, be easy to simply point out the problems or to provide solutions that worked elsewhere--but if they aren't viable for this client location, you have not met your obligation, nor have you added value. Remain flexible and look for the proper solution for this client.

The Bottom Line
These are obviously only brief examples of approaches for the large variety of services provided by EHS consultants. However, in all cases (those discussed above and those not covered), our challenge as consultants is to leave a client company (or our own company if serving as an internal consultant) better off as a result of our efforts.

While this can be difficult, especially when dealing with clients (and employers) that want the "easy quick fix," the positive results are well worth the effort. Unless we approach the opportunities in this fashion, we become more a part of the problem and less a part of the solution ourselves.

This article originally appeared in the January 2004 issue of Occupational Health & Safety.

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