Regulations Versus Management Practices

JOHN HAMRIC: Our next speakers are Richard Ghent, manager of environmental health and safety for CF Industries, Hardee Phosphate Complex, in Wauchula, Florida. Richard has 20 years' experience with environmental health and safety affairs. He has a bachelor of science degree from the University of South Carolina. With him is Daniel Warnock, who is supervisor of safety and training also at the Hardee Phosphate Complex. Daniel's experience is in safety programs and electrical training. Their presentation is "Regulations Versus Management Practice." RICHARD GHENT: Written procedures give structure to safety programs. At their best, they are brief and understandable to facility personnel and clearly identify roles and responsibilities. At worst, they attempt to recite the entire regulation they are intended to address. Some regulations, such as OHSA's Hazard Communication Standard, require employers to develop, implement, and maintain a written program. As written programs and procedures are developed, some basic questions arise: Is the program designed to achieve compliance with regulatory requirements or does management expect the program to go beyond compliance to some higher level of performance? Management may have difficulty in measuring and communicating performance expectations in safety. A facility with 4 million safe work hours does not suddenly become unsafe the day their safety record is broken. Generally, management expects safety programs to meet regulatory requirements and to protect the employer from enforcement actions and fines from regulatory agencies. Management also expects that safety programs will result in a safer work environment with fewer incidents, accidents, and near misses. But it is difficult to know when a safety program has succeeded. If the program is expected to go beyond compliance, what other standards should be included (e.g., ANSI standards, company management practices, lessons learned from inspections and audits, recommendations from safety committees, etc.) in the