seminating new controls and corrective actions. If requirements are perceived by laboratory personnel as unnecessarily onerous, there is potential for lower compliance within the organization and a loss of credibility on the part of EHS personnel. While understanding that some individuals will never be convinced of the need for new controls, it is important to provide clear, supported justifications for changes to existing protocols to encourage adoption of the new policies and procedures.

2.A.4 Implementation

The design of management arrangements should reflect the organization’s business needs and the nature of their risks. However, there should be appropriate activity across all elements of the model (policy; planning; implementation; performance measurement, audits, and change management; and management review).

Specifically the organization should make arrangements to cover the following key areas:

   overall plans and objectives, including employees and resources, for the organization to implement its policy;

   operational plans to implement arrangements to control the risks identified;

   contingency plans for foreseeable emergencies and to mitigate their effects (e.g., prevention, preparedness, and response procedures);

   plans covering the management of change of either a permanent or a temporary nature (e.g., associated with new processes or plant working procedures, production fluctuations, legal requirements, and organizational and staffing changes);

   plans covering interactions with other interested parties (e.g., control, selection, and management of contractors; liaison with emergency services; visitor control);

   performance measures, audits, and status reviews;

   corrective action implementation;

   plans for assisting recovery and return to work of any staff member who is injured or becomes ill through work activities;

   communication networks to management, employees, and the public;

   clear performance and measurement criteria defining what is to be done, who is responsible, when it is to be done, and the desired outcome;

   education and training requirements associated with EHS;

   document control system; and

   contractors should have written safety plans and qualified staff whose qualifications are thoroughly reviewed before a contract is awarded. All contractor personnel should be required to comply with the sponsoring organization’s safety policies and plans.

Though it is the responsibility of each individual researcher to ensure that work is performed in a prudent and safe manner, achieving a safe laboratory environment is a cooperative endeavor between management, EHS personnel, and laboratory personnel. Regulations, policies, and plans will never cover every contingency, and it is important for these different groups to communicate with each other to ensure that new situations can be handled appropriately. One way to ensure that the needs of all groups are being met is by creating safety committees consisting of representatives from each part of an organization. In this forum, safety concerns can be raised, information can be distributed to affected parties, and a rough sense of the efficacy of policies and programs can be gained.

2.A.5 Performance Measurement and Change Management

The primary purpose of measuring EHS performance is to judge the implementation and effectiveness of the processes established for controlling risk. Performance measurement provides information on the progress and current status of the arrangements (strategies, processes, and activities) used by an organization to control risks to EHS. Measurement information includes data to judge the management system by

   gathering information on how the system operates in practice,

   identifying areas where corrective action is necessary, and

   providing a basis for continual improvement.

All of the components of the EHS management system should be adequately inspected, evaluated, maintained, and monitored to ensure continued effective operation. Risk assessment and risk control should be reviewed in the light of modifications or technological developments. Results of evaluation activities are used as part of the planning process and management review, to improve performance and correct deficiencies over time.

Periodic audits that enable a deeper and more critical appraisal of all of the elements of the EHS management system (see Figure 2.1) should be scheduled and should reflect the nature of the organization’s hazards and risks. To maximize benefits, competent persons independent of the area or activity should conduct the audits. The use of external, impartial auditors should be considered to assist in evaluation of the EHS man-

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