For many organizations, hazardous materials management is not constrained by a lack of effort. The bigger challenges often lie in disconnected systems, lean staffing, and the ongoing need to keep regulatory information, records, and institutional knowledge organized. Southeast Missouri State University (SEMO) faced these pressures across a complex campus environment and needed a practical, sustainable way to manage environmental compliance and hazardous materials without adding unnecessary software complexity.

The case study below highlights how effective hazardous materials management depends less on buying a standalone system and more on designing clear processes, centralizing reliable information, and making compliance tasks easier for the people who perform them. SEMO’s solution did just that by leveraging tools already familiar to many organizations: Microsoft SharePoint and the Power Platform.

Challenge: Too Many Requirements, Too Few Resources

SEMO’s environmental, health, and safety (EHS) responsibilities span a broad campus footprint: approximately 9,000 students, 1,100 employees, 397 acres, 99 buildings, about 100 laboratories, and 17 residence halls. The University’s EHS profile further includes dual-fuel and natural gas boilers, generators, oil storage tanks, a Title V air permit, a Municipal Separate Storm Sewer System (MS4) permit, a Spill Prevention, Control, and Countermeasure (SPCC) Plan, and hazardous waste small quantity generator (SQG) obligations.

The scale of SEMO’s operation creates a significant documentation and coordination burden, especially when hazardous materials, environmental permits, inspections, training, and waste activities must be managed consistently. And with only two EHS Facilities Management team members, the University needed processes that were visible, repeatable, and less dependent on individual staff capacity to manage, sustain, and communicate compliance.

Drivers: Practical Needs, Budget Constraints, and Continuity

SEMO’s immediate need was not to collect more EHS information; it was to make that information usable. SEMO needed better systems for managing general EHS information, Safety Data Sheet (SDS) management, chemical inventory management, and hazardous waste tracking, along with a way to preserve institutional knowledge and maintain continuity when staffing changes occurred.

Budget was also a design constraint. Commercial EHS software can be expensive and difficult to justify within a Facilities Management budget, so SEMO needed a solution that delivered meaningful functionality while avoiding a major new software investment.

Solution: A Compliance-Focused SharePoint and Power Platform Management System

SEMO worked with KTL to build the system from a compliance-first foundation. The project began with an environmental compliance audit and report, followed by an EHS management system assessment. Those findings informed development of a broader EHS compliance management system that used SEMO’s existing Microsoft 365 environment and the Power Platform to connect webpages, documents, data, mobile forms, and automated notifications in one familiar platform.

Recent enhancements focused on hazardous materials management capabilities within the larger EHS compliance management system. Each tool was designed to address a specific operational need: knowing what materials are on campus, standardizing waste pickup requests, documenting waste determinations, and maintaining training records.

• Chemical Inventory Tool gives SEMO a structured way to view and manage chemicals throughout campus. Chemicals are associated with rooms and maintained alongside PDFs of related SDSs, inventory details, hazard information, and CAS numbers. Through a web-based interface, users can search, filter, and access records for the rooms they manage, improving visibility into what materials are present, where they are located, and what hazards are associated with them. The Chemical Inventory Tool also generates a list of chemicals that need to be reported, making regulatory reporting easier and more streamlined.
• Waste Pickup Process and Notification Workflow allows staff to request waste chemical pickups through a defined process instead of relying on informal disposal decisions. The workflow supports request submission, routing to EHS, waste determination, and notifications. This reduces manual follow-up, improves response consistency, and creates a clearer record of pickup activity.
• Waste Determination Form supports the Waste Pickup Process by providing a structured process for disposal decisions. It captures basic information, waste properties, characteristics, constituents, attachments, RCRA values, review status, and EHS determinations. Completed waste determinations can then be referenced in future waste pickups to support proper disposal.
• Lab Safety Training Module supports standardized training delivery and documentation for students and faculty using University laboratories. This helps SEMO maintain training records and reinforce consistent expectations for personnel working with hazardous materials.

Results and Benefits

By developing an EHS compliance management system with dedicated hazardous materials management tools in SharePoint and the Power Platform, KTL helped SEMO create a more sustainable model for managing EHS compliance. The system centralizes records, improves document retrieval, supports regulatory inspection readiness, monitors performance, and creates a stronger foundation for continual improvement. It also captures institutional knowledge, so essential processes are less dependent on one person’s habits, memory, or manner of organizing files.

For organizations already using Microsoft 365, this approach can reduce barriers to adoption because users work in a familiar environment, IT can support the platform internally, and the organization can adapt forms, lists, workflows, dashboards, and pages as needs evolve. As SEMO has demonstrated, effective EHS compliance and hazardous materials management do not always require a large software purchase. With the right framework, clear process design, and thoughtful use of SharePoint and the Power Platform, organizations can centralize information, reduce administrative burden, preserve institutional knowledge, and strengthen regulatory compliance using tools they already have.tralize information, reduce administrative burden, preserve institutional knowledge, and strengthen regulatory compliance.

Ready-to-eat (RTE) fresh-cut produce is convenient and widely consumed, but it also presents elevated food safety risk. Because these products are distributed fresh and generally do not undergo a kill step, the risk of contamination across the supply chain is significant, whether during growing and harvesting, transportation, manufacturing, commingling, retail handling, or even consumer use. Recent outbreaks and recalls due to fresh-cut produce contamination reinforce the potential magnitude of this concern.

The Food Safety Modernization Act (FSMA) Current Good Manufacturing Practice, Hazard Analysis and Risk-Based Preventive Controls for Human Food (PSHF) rule requires fresh-cut produce operations to follow current Good Manufacturing Practices (cGMPs) and implement risk-based preventive controls. To help manufacturers and processors comply with the PCHF rule, the Food and Drug Administration (FDA) recently announced an update to its Guide to Minimize Biological Hazards in Ready-to-Eat Fresh-Cut Produce, originally published in 2008.

Guidance for Compliance

Fresh-cut produce includes fruits and vegetables that have been physically altered from their whole state (e.g., chopped lettuce, cut melon, diced onions, shredded carrots, peeled fruit, or trimmed vegetables) and distributed in fresh form without additional processing. This cutting, peeling, coring, shredding, or trimming can expose nutrient-rich internal tissues, create surfaces where microorganisms can attach and grow, and spread contamination from one item or surface to many others during processing.

The risk is amplified because many fresh-cut products are ready-to-eat (RTE) and do not undergo a lethality treatment (or kill step) before they reach consumers. Once introduced, pathogens can persist in equipment niches, biofilms, drains, standing water, employee traffic patterns, and other areas of the processing environment.

FDA’s updated 2026 guidance translates the PCHF rule framework into practical controls for fresh-cut produce. The core message is straightforward: processors must rely on strong preventive systems, supported by documented monitoring, verification, and corrective action, to minimize biological contamination.

Key Provisions and Expectations

FDA’s updated guidance aligns fresh-cut produce operations with cGMP and Hazard Analysis and Risk-based Preventive Controls (HARPC) requirements in 21 CFR Part 117. For RTE fresh-cut produce, the emphasis is on integrated controls that reflect the product, process, facility environment, and intended use. Facilities should evaluate reasonably foreseeable hazards, determine which hazards require preventive controls, and implement written controls with monitoring, corrective actions, verification, validation where appropriate, and records, as follows:

• Food Safety Plan: Develop, implement, and maintain a written plan that identifies hazards (primarily biological), preventive controls, monitoring procedures, corrective actions, verification activities, and recordkeeping.
• Hazard Analysis: Evaluate the product, ingredients, process steps, equipment, facility layout, intended use, storage conditions, and likelihood that consumers will eat the product without further processing.
• Sanitation Controls: Address cleaning and sanitizing of food-contact surfaces, prevention of cross-contamination, hygienic zoning, employee practices, glove and utensil controls, traffic flow, and management of drains and wet areas.
• Supply Chain Controls: Verify that suppliers adequately control hazards in raw produce and other ingredients when those hazards are controlled before receipt.
• Process and Temperature Controls: Use refrigeration, time limits, wash water controls, and other validated parameters to minimize pathogen growth and cross-contamination.
• Environmental Monitoring: Use risk-based monitoring where RTE product is exposed to the environment and contamination with environmental pathogens is a reasonably foreseeable hazard.
• Corrective Actions and Verification: Investigate deviations, prevent affected product from entering commerce when safety is uncertain, verify that controls are operating as intended, and maintain complete records.

Best Practices and Key Actions

FDA’s guidance is most useful when translated into daily operating practices. Fresh-cut produce processors and manufacturers should leverage the guidance to evaluate whether preventive controls are built into each point where product, people, equipment, water, and the processing environment can introduce or spread contamination.

1. Strengthen Raw Material and Supplier Controls. Fresh-cut produce safety begins before the product reaches the processing line. Manufacturers should maintain supplier approval programs that consider growing practices, harvest conditions, water sources, field sanitation, transportation, prior supplier performance, and relevant outbreak or recall history. Receiving procedures should include lot identification, condition checks, temperature checks where applicable, and documentation that supports traceability.

Key actions: Update the hazard analysis by commodity and intended use; verify supplier approval criteria, incoming lot records, audit or certificate documentation where used, and supplier corrective action history.

2. Control Water as a Potential Vehicle for Cross-Contamination. Water management is one of the most important controls in a fresh-cut produce facility. Wash and process water can reduce surface contamination when properly controlled, but unmanaged water can also move pathogens quickly across lots, equipment, and finished product contact areas. Water used for washing, cooling, fluming, ice, equipment cleaning, and employee hygiene must be managed to prevent it from becoming a contamination source.

Key actions: Define water quality expectations; confirm water quality standards, antimicrobial levels where used, monitoring frequency, corrective actions, documentation, and any temperature or organic-load limits (turbidity) needed to prevent cross-contamination; document corrective actions when parameters fall outside established limits.

3. Design Sanitation Programs Around Product Exposure. Sanitation programs need to reflect how fresh-cut produce is actually exposed during production. Because cutting and handling create more product contact surfaces, sanitation procedures should focus on both visible soil removal and the less obvious niches where microorganisms can persist. Effective programs include defined cleaning frequencies, validated cleaning methods, sanitizer concentrations and contact times, pre-operational inspections, ATP or microbiological verification as appropriate, and heightened attention to hard-to-clean areas (e.g., slicers, dicers, peelers, conveyors, hollow rollers, gaskets, drains, floors, splash zones, and equipment framework).

Key actions: Verify that cleaning procedures reach equipment niches, sanitation frequencies are risk-based, post-sanitation inspections are documented, and maintenance-related sanitation controls are effective.

4. Use Hygienic Zoning and Traffic Controls. Hygienic zoning provides the structure to keep controls consistent across shifts, products, equipment changes, and maintenance activities. Processors should separate raw, in-process, and RTE exposure areas to prevent transfer of pathogens through people, equipment, tools, air, water, condensation, forklifts, totes, and maintenance activities. Where physical separation is not possible, facilities should establish procedural barriers (e.g., dedicated tools, color coding, footwear controls, handwashing and glove-change requirements, controlled employee movement, and documented sanitation after maintenance or production interruptions).

Key actions: Map product and personnel flow to identify crossover points, splash risks, shared tools, employee movement patterns, and opportunities for raw-to-RTE contamination; reinforce training on handwashing, glove use, illness reporting, traffic controls, and escalation procedures.

5. Build a Robust Environmental Monitoring Program (EMP). Environmental monitoring verifies whether sanitation and zoning controls are working as intended. In RTE fresh-cut produce areas, a well-designed EMP should identify patterns, recurring risks, areas of concern, and opportunities to strengthen controls before product safety is affected. The EMP should define the test organism, sampling zones, number and location of sites, timing, frequency, analytical method, laboratory, corrective action procedures, and trend review. Positive findings should trigger timely investigation, intensified cleaning, resampling, and evaluation of whether product may have been affected.

Key actions: Strengthen environmental monitoring by using trend data to identify recurring sites, persistent organisms, sanitation weaknesses, maintenance-related risks, and conditions requiring corrective or preventive action.

6. Maintain Temperature Control Through Distribution. Temperature control extends food safety beyond production to transportation, storage, retail handling, and consumer-facing conditions. Because many fresh-cut products support microbial survival or growth, refrigeration and time control are critical. Facilities should define temperature limits for receiving, processing, storage, and distribution; monitor those limits; evaluate deviations; and coordinate with carriers and customers to prevent temperature abuse after product leaves the facility.

Key actions: Verify receiving, processing, storage, and distribution temperature limits; evaluate deviations; coordinate expectations with carriers and customers; test traceability and recall readiness through mock recalls.

Bottom Line

FDA’s 2026 updated guidance reinforces that fresh-cut produce safety depends on prevention, not end-product correction. For manufacturers and processors, the priority is to use the guidance to evaluate whether the Food Safety Plan is both adequate for an RTE, no-kill-step product and fully implemented throughout the facility. Processors and manufacturers that do so will be better positioned to reduce biological risk, strengthen compliance, and protect consumers.nforces that fresh-cut produce safety depends on prevention, not end-product correction. For manufacturers and processors, the priority is to use the guidance to evaluate whether the Food Safety Plan is both adequate for an RTE, no-kill-step product and fully implemented throughout the facility. Processors and manufacturers that do so will be better positioned to reduce biological risk, strengthen compliance, and protect consumers.

KTL will be a featured poster presenter and panelist at the 2026 Master Brewers Conference in Virginia Beach, Virginia, October 22-24, 2026. Hosted by the Master Brewers Association of the Americas (MBAA), the Master Brewers Conference brings together brewing professionals from across the globe to share technical knowledge, explore new technologies, and network with industry leaders. The Conference’s mission is to advance the brewing industry through education and collaboration.

Where to Find Us

• Campfire Session (October 22, 2027 | 11:00-12:15 am): KTL will be a featured panelist on the Q&A panel Safety Queries and Quandaries: Ask the Brewer & Food Safety Committee.

• Poster Session: KTL will be co-presenting a poster session with New Belgium Brewery on Food Safety and Regulatory Implications of Producing Nonalcoholic and Low-Alcohol Beer (NALAB).

We look forward to connecting with you in Virginia Beach!

All types of organizations and operational processes demand a variety of audits and assessments to evaluate compliance with requirements, ranging from government regulations, to industry codes, to management system standards (e.g., ISO, GFSI), to internal obligations. Audits and assessments capture regulatory compliance status, management system conformance, supplier compliance, adequacy of internal controls, potential risks, and best practices. In short, audits and assessments are essential for improving and verifying compliance performance, internal controls, potential risks, and best practices.

Having the right tool for the job can make audits significantly more efficient. This includes the protocol and templates developed as part of pre-audit preparation, as well as audit/assessments tools that may be used to conduct and manage audits more efficiently and effectively. The KTL Assessment App is a comprehensive audit management solution built on the Microsoft Power Platform and Dataverse that enables organizations to more efficiently create, manage, and execute audits, while managing and tracking corrective actions.

Functionality: What does it do?

KTL’s Assessment App supports the entire audit lifecycle. Users can conduct audits and assessments from desktop or mobile devices, record responses, capture comments, attach photos, track progress, and assign corrective actions. The app features a fully customizable framework that enables organizations to build robust audit programs tailored to their specific regulatory, operational, and business requirements.

The solution works through three applications:

• Assessment Report App: The Assessment Report App allows managers to review audit findings and manage corrective actions. The application supports PDF report generation and sharing to improve communication and compliance documentation.
• Assessment Management App: The Assessment Management App serves as the administrative hub. Administrators can create and manage assessment templates, data, and configuration settings.
• Assessment App: The Assessment App is the primary user-facing application used to conduct audits and assessments. Available on desktop and mobile devices, it allows auditors to view audits, answer questions, upload supporting evidence, and track progress. Scoring and progress tracking provide real-time insight into assessment progress.

Benefits: Why do you need it?

KTL’s Assessment App helps organizations manage audits and assessments more consistently, efficiently, and transparently. By centralizing setup, execution, reporting, and corrective action tracking, the app improves visibility into audit status, strengthens accountability, and supports better compliance decision-making.

• Program setup and administration: Add and manage users, locations, standards, audit types, assessment templates, and scoring models.
• Audit execution: Record responses, comments, and supporting evidence; monitor assessment progress and completion status in real time; and automatically calculate scores throughout the audit process.
• Reporting and decision support: Generate reports and PDF summaries that support compliance reviews and provide management with clear information for decision-making.
• Corrective action management: Track corrective actions to ensure findings are assigned, addressed, and resolved.
• Data security: Protect assessment data through role-based access controls and permissions.

With assessment management, automation, reporting, and corrective action tracking in one platform, KTL’s Assessment App gives organizations a more reliable way to manage audit programs, capture compliance status, identify trends, and drive continuous improvement.

Technology Used

• Dataverse
• Power Apps
• Power Automate

KTL will be exhibiting at the Wisconsin Correctional Association’s (WCA) 2026 Annual Training Conference in Wisconsin Dells September 20-22, 2026. WCA hosts this annual statewide conference to bring together correctional professionals, students, and leaders across the criminal justice system. The event supports collaboration, professional development, and meaningful dialogue around the future of corrections.

Be sure to stop by and visit KTL at our exhibit booth (#18). We’ll be sharing more about our EHS, food safety, and Microsoft 365 information management solutions. We look forward to connecting with you in the Dells!

Food Safety System Certification (FSSC) 22000 is a robust Global Food Safety Initiative (GFSI)-recognized food safety certification scheme based on ISO 22000 that is applicable across the food chain (i.e., food/feed manufacturing, packaging production, transport, and storage). As a certification scheme, FSSC 22000 is unique in that it comprises three separate elements:

• ISO 22000 International Standard – Specifies requirements for a food safety management system (FSMS) in alignment with the ISO Harmonized Structure.
• ISO/Sector-Specific Technical Specifications (TS) 22002 – Requires organizations to establish Prerequisite Programs (PRPs) for specific sectors.
• FSSC 22000 Scheme Additional Requirements – Provides comprehensive additional requirements that build on ISO 22000 and sector-specific PRPs.

With recent updates to the FSSC 22000 Scheme (i.e., Version 7) and ISO/TS 22002, as well as planned updates (2027) to the ISO 22000 Standard, there is a lot of confusion surrounding applicable requirements, how they are related, and compliance timelines. KTL’s Q&A with our food safety experts helps clarify some of the commonly asked questions regarding ISO 22000 and FSSC 22000.

How do ISO 22000 and FSSC 22000 work together?

ISO 22000 is an internationally recognized FSMS standard for any organization in the food chain, regardless of size or role. It combines management system practices, risk-based thinking, PRPs, interactive communication, and Hazard Analysis and Critical Control Points (HACCP) principles to help organizations identify, prevent, control, and continually improve how they manage food safety hazards.

FSSC 22000 is a food safety certification scheme built on ISO 22000. It includes ISO 22000, applicable sector-specific PRP standards (ISO/TS 22002), and FSSC 22000 Additional Requirements. The scheme is managed by Foundation FSSC and is benchmarked by GFSI, which is why many global brands, retailers, manufacturers, and buyers recognize or require it.

ISO 22000 provides the core FSMS framework and can stand on its own. In turn, FSSC 22000 uses that framework as its foundation and adds a more prescriptive certification structure. In practical terms, a company with a well-implemented ISO 22000 system has already built much of the foundation needed for FSSC 22000, but it must still address the applicable PRP standard, FSSC Additional Requirements, scheme rules, audit expectations, and certification body requirements.

What is the main difference between ISO 22000 and FSSC 22000?

ISO 22000 and FSSC 22000 are closely connected, but they are not interchangeable. The main differences between the standards are related to certification scope and market recognition. ISO 22000 defines what an organization must do to control food safety hazards across the food chain. FSSC 22000 builds on ISO 22000 by adding sector-specific PRP requirements, FSSC Additional Requirements, scheme rules, and GFSI-recognized certification used to satisfy major customer, retailer, and procurement expectations. This includes additional requirements for areas such as food defense, food fraud mitigation, allergen management, environmental monitoring, equipment management, and food safety and quality culture.

What does my facility need to do to comply with the three elements of FSSC 22000?

To comply with FSSC 22000, a facility must implement all three elements (i.e., ISO 22000, ISO/TS 220002, FSSC 22000 Additional Requirements) as one integrated FSMS, not as separate documents or checklists, as follows:

1. ISO 22000: Define the FSMS scope; assign leadership responsibilities; identify internal and external risks; establish food safety objectives; complete hazard analysis; define PRPs, operational prerequisite programs (OPRPs), and critical control points (CCPs); control monitoring and corrective actions; maintain traceability and recall processes; conduct internal audits; complete management review; and drive continual improvement.
2. ISO/TS 22002: Identify and implement applicable sector-specific PRP requirements from the ISO 22002 series; translate the relevant TS into site controls for areas such as zoning, facility design, equipment, cleaning and sanitation, pest management, utilities, personnel hygiene, storage, transport, waste handling, maintenance, supplier controls, and prevention of cross-contamination; verify that these PRPs are effective, current, and supported by records, not just written into procedures.
3. FSSC 22000 Scheme Additional Requirements: Meet applicable requirements for purchased services and materials, product labeling, food defense, food fraud mitigation, allergen management, environmental monitoring, equipment management, food safety and quality culture, quality control, transport and delivery, and any other requirements that apply to the facility’s food chain category and certification scope.

A documented gap assessment against ISO 22000, the applicable ISO/TS 22002 PRP standard, and the FSSC 22000 requirements is a practical place to start. Facilities can then work to convert the gaps into an implementation plan with assigned responsibilities, training, verification activities, internal audit checks, and management review follow-up to ensure effective implementation.

What are the recent changes to the ISO/TS 22002 PRPs?

The ISO/TS 22002 series was modernized in 2025. The new structure introduces ISO 22002-100 as a common baseline for food, feed, and packaging supply chains, supported by sector-specific parts to create a more consistent PRP framework and help simplify implementation for organizations operating across multiple sectors. Sector-specific categories are defined as follows:

• ISO/TS 22002-1: Food Manufacturing
• ISO/TS 22002-2: Catering
• ISO/TS 22002-3: Farming
• ISO 220002-4: Food Packaging
• ISO/TS 22002-5: Transport and Storage
• ISO/TS 22002-6: Feed and Animal Food Production
• ISO/TS 22002-7: Retail and Wholesale Operations
• ISO/TS 22002-100: Common/General Requirements 

With this change, every certified facility must now comply with ISO/TS 22002-100, which consolidates general, common requirements across the entire supply chain, while also implementing their sector-specific requirements. The ISO/TS 22002 updates also demand tighter focus related to hygienic design and zoning, material and chemical control, and allergen and environmental monitoring.

The release of the restructured ISO/TS 22002:2025 series serves as the primary driver behind the creation of FSSC 22000 Version 7 (V7). As such, the timeline for compliance with the ISO/TS 22002:2025 series is tied directly to the FSSC 22000 transition to V7. See below.

What is changing in FSSC 22000 V7?

In early May 2026, Foundation FSSC published V7 of the FSSC 22000 Scheme Additional Requirements. It aligns the scheme with the updated ISO/TS 22002:2025 PRP series and GFSI benchmarking requirements, updates food chain categories, strengthens select Additional Requirements, and introduces a new requirement related to sustainable packaging design principles for organizations involved in packaging design or packaging material changes. V7 also updates auditor qualification requirements and transition expectations.

FSSC has established a phased transition from V6 to V7. Audits against V6 are allowed only up to April 30, 2027. Updated audits against V7 are expected to take place from May 1, 2027 through April 30, 2028. Again, this includes the updated ISO/TS 22002:2025 requirements.

What changes are expected for ISO 22000 in 2027?

ISO 22000:2018 remains the current certifiable edition, but a revised ISO 22000 standard is anticipated in 2027. The revision is expected to strengthen food defense, food fraud, and food safety culture; clarify the relationship between CCPs, OPRPs, and PRPs; and support alignment with the updated ISO/TS 22002 PRP series.

Should I wait for ISO 22000:2027 before pursuing certification?

No. Companies should continue to implement, maintain, and improve their systems against the currently applicable requirements. Waiting for the updated ISO 22000 standard may delay customer approvals, weaken audit readiness, and create a larger transition burden later. Organizations should focus on the changes associated with FSSC 22000 V7 and ISO/TS 22002 and strengthening core FSMS disciplines, including hazard analysis, PRP effectiveness, traceability, management review, internal auditing, corrective action, supplier approval, food defense, food fraud mitigation, and food safety culture.

What should I do now?

With ISO/TS 22002 and FSSC 22000 V7 now released and ISO 22000 expected to be revised in 2027, food companies should use the transition period to modernize PRPs, strengthen intentional risk controls, make food safety culture measurable, and prepare evidence that their food safety system works in practice:

• Map your current system against the applicable requirements. Conduct a clause-by-clause and process-by-process gap assessment. This should include ISO 22000, the relevant ISO/TS 22002 PRP standard, FSSC 22000 V7 Additional Requirements. Identify gaps that need to be addressed to meet the updated requirements.
• Plan the FSSC 22000 V7 transition early. Build a transition plan based on the gap assessment that includes document updates, PRP revisions, personnel training, internal auditor training, supplier communication, validation or verification activities, internal audits, management review, and certification body scheduling.
• Update PRPs using the new ISO/TS 22002 structure. Review sanitation, zoning, personnel hygiene, utilities, pest control, maintenance, supplier controls, waste handling, storage, transport, and other PRP elements against the updated ISO 22002-100 baseline and the relevant sector-specific part. Multisite or multisector companies should coordinate shared PRPs while preserving site-specific controls.
• Strengthen intentional risk programs. Food defense and food fraud are becoming increasingly prominent in both FSSC 22000 and the expected ISO 22000 revision. Maintain documented threat and vulnerability assessments, define mitigation measures, verify controls, and review these programs when products, suppliers, materials, processes, or geopolitical risks change.
• Make food safety culture auditable. Food safety culture should be a lived organization value. Define leadership expectations, employee behaviors, communication methods, training needs, escalation practices, and measurable indicators. Use internal audits, management review, employee feedback, and corrective action trends to show that food safety responsibilities are understood and practiced throughout the organization.

At the core of every effective safety and health program is a systematic process for identifying and controlling workplace hazards. OSHA’s Safe & Sound framework refers to this as “find-and-fix hazards,” an ongoing approach that helps organizations identify sources of potential injury or illness, evaluate risks, and implement controls before harm occurs.

Why Find-and-Fix Matters

Traditional safety efforts are often reactive; corrective action begins after a worker is injured, a regulatory requirement changes, or an outside inspection identifies a problem. A robust safety and health program takes a more proactive approach. It uses available information, worker input, routine inspections, incident investigations, and the hierarchy of controls to find hazards early and fix them effectively.

Workplaces are constantly changing. New equipment, materials, technologies, processes, schedules, contractors, and workers can introduce new or emerging hazards. A systematic find-and-fix process helps organizations stay ahead of those changes instead of relying on luck, memory, or post-incident response.

Inspect for New and Emerging Hazards

Routine inspections (vs. reactive) are key to finding hazards before they cause harm. Inspections should look beyond obvious physical conditions and consider how work is performed, how equipment is used, whether controls are intact, and whether workers face risks during setup, maintenance, cleaning, troubleshooting, emergency response, or other nonroutine activities.

Practical activities such as safety walkarounds, checklist challenges, hazard hunts, and job swaps can help workers and managers look at tasks from a fresh perspective, identify hazards that may have become normalized, and improve understanding across teams. Encouraging worker participation, including helping conduct safety walkarounds, developing checklists, reviewing job tasks, evaluating equipment, identifying nonroutine hazards, testing controls, and verifying whether corrective actions actually solve the problem, can significantly strengthen hazard identification.

Use Available Information

Information is important if it’s effectively used. The value comes from looking for patterns, prioritizing risks, and turning findings into corrective actions. For example, recurring minor injury, repeated equipment issue, frequent near miss, or worker concern may indicate a larger hazard that needs attention.

As such, organizations need to review all available information about hazards that may be present in the workplace, including injury and illness records, near-miss reports, worker concerns, safety data sheets (SDS), equipment manuals, inspection findings, maintenance records, job hazard analyses (JHAs), audit results, emergency response information, and lessons learned from similar operations.

Investigate Root Causes

Incidents, injuries, illnesses, near misses, and close calls provide important information about where controls may be missing, weak, or ineffective. Investigations should focus on root causes and contributing factors, not blame. The goal is to understand what happened, why it happened, and what system improvements are needed to prevent recurrence.

Root cause analysis may point to gaps in training, communication, equipment design, maintenance, staffing, supervision, procedures, contractor coordination, procurement, or change management. Addressing these underlying issues improves the program more than correcting only the immediate condition.

Prioritize Controls Using the Hierarchy of Controls

Once hazards are identified, organizations need to evaluate control options using the hierarchy of controls as a framework for prioritizing solutions. The most effective controls eliminate the hazard or substitute a safer process, material, or equipment. Engineering controls, administrative controls, safe work practices, and personal protective equipment (PPE) may also be needed, but they should not be the only line of defense when stronger controls are feasible.

A strong find-and-fix process also considers urgency and feasibility. Serious hazards that could cause severe injury, illness, or exposure should be addressed promptly. Interim controls may be needed while permanent solutions are designed, funded, and implemented. Corrective actions should have owners, deadlines, verification steps, and follow-up to ensure controls remain effective.

Controls need to be checked to confirm they remain intact, effective, and appropriate for current conditions. This verification should be built into the safety and health program. Supervisors and workers should confirm that controls are working, corrective actions are closed, and any unintended consequences are addressed to close the loop and keep hazard control from becoming a one-time activity.

Practical Actions to Find and Fix Hazards

• Review injury and illness records, near-miss reports, worker concerns, inspection findings, safety data sheets, equipment manuals, and maintenance data.
• Conduct routine safety walkarounds with managers, supervisors, and workers.
• Involve workers in identifying hazards, evaluating controls, and confirming whether fixes work.
• Investigate incidents and near misses to identify root causes and system improvements.
• Prioritize controls using the hierarchy of controls, emphasizing elimination, substitution, and engineering controls where feasible.
• Assign corrective action owners, deadlines, resources, and verification steps.
• Review completed corrective actions and existing controls to confirm they remain effective over time.

Hazard Control Is Continuous Improvement

Finding and fixing hazards is what turns a safety and health program into daily prevention. It brings leadership commitment and worker participation together around a clear purpose: identifying what could harm people and taking action before it does. When organizations use a systematic process to collect information, inspect work areas, involve workers, investigate root causes, apply effective controls, and verify results, they create a safer workplace and a stronger foundation for long-term business performance.

Worker participation is essential to a robust safety and health program, because workers are closest to the work, the hazards, and the practical realities that shape day-to-day risk. As such, it is also one of the three core elements of OSHA’s Safe & Sound framework for creating a sustainable safety and health program.

What Does Worker Participation Entail?

Worker participation is more than just attendance at a safety meeting. OSHA defines worker participation as involvement in establishing, operating, evaluating, and improving the safety and health program. That includes employees, contractors, subcontractors, temporary workers, and worker representatives.

Effective safety and health programs tap into workers’ collective experience, knowledge, and insight to find solutions to workplace safety and health challenges. When workers are meaningfully involved, not just informed after decisions are made, they help identify hazards earlier, improve controls, strengthen trust, and build shared ownership for safety performance.

Why Worker Participation Matters

Workers often know the most about the hazards associated with their jobs because they perform the tasks, adapt to changing conditions, and see where procedures work (or do not work) in real time. Their involvement helps organizations move beyond paper compliance into practical risk reduction. Organizations can miss critical risk information when they do not create reliable ways for workers to speak up and participate. Worker participation also creates buy-in. When workers are part of identifying problems and shaping solutions, they are more likely to understand, support, and sustain the controls that result.

Build Trust Before You Ask for Participation

Participation depends on trust. Workers must feel comfortable raising concerns, reporting injuries and illnesses, identifying near misses, and sharing ideas without fear of blame or retaliation. This is known as psychological safety. To encourage participation, the organization must remove barriers related to fear of discipline, lack of time, poor communication, limited access to safety information, language or literacy challenges, production pressure, or the belief that nothing will change after a concern is reported.

Further, communication across the organization must be clear, consistent, and two-way. Management needs to communicate expectations, but workers also need to feel empowered to discuss safety concerns. Active listening is part of engendering trust. If workers raise issues but rarely see follow-up, participation will decline. If leaders respond promptly, explain decisions, and close the feedback loop, participation becomes a normal part of how work gets done.

Involve Workers Across the Program Lifecycle

Meaningful participation should extend across the full safety and health program lifecycle. Workers can help develop the initial program, report incidents and near misses, analyze routine and nonroutine tasks, define safe work practices, participate in inspections and incident investigations, train coworkers and new hires, evaluate program performance, and recommend improvements. Employees feel truly engaged when they are part of the system, their input is valued, and their experience helps shape decisions.

Use Small Improvements to Build Momentum

Participation grows when workers see practical progress. Small wins (e.g., fixing a recurring housekeeping issue, improving signage, simplifying a procedure, updating training based on worker feedback, or correcting an awkward task design) show that input leads to action.

Incremental improvement also makes participation less overwhelming. Instead of asking workers to solve an entire safety management system at once, leaders can invite them to identify one hazard, test one control, review one procedure, or improve one task. Over time, these small steps build a stronger culture of ownership and continuous improvement.

Practical Actions to Strengthen Worker Participation

• Give workers time and resources to participate in safety activities, inspections, training, and improvement projects.
• Allow anonymous reporting where appropriate and clearly prohibit retaliation for raising safety concerns.
• Share safety information workers need to participate effectively, including procedures, incident trends, inspection findings, and corrective action status.
• Involve workers in job hazard analyses, incident investigations, emergency planning, inspections, procedure development, and program evaluation.
• Use multiple communication channels, including one-on-one conversations, toolbox talks, written updates, visual aids, and team meetings.
• Report back on what changed as a result of worker input.
• Recognize workers and teams for identifying hazards, improving controls, helping coworkers, and contributing practical solutions.
• Use small, achievable improvements to build momentum and demonstrate that participation matters.

Turn Programs into Practice

A safety and health program cannot succeed as a management document alone. It must be lived in the work environment, tested against real conditions, and improved by the people who understand the work best. When workers are encouraged to participate, heard when they speak up, included in decisions, and shown that their input leads to action, participation becomes engagement. That engagement turns a safety and health program into a practical, trusted system for preventing harm and strengthening business performance.

Management leadership is the foundation of an effective safety and health program, one of the defining characteristics of a strong safety culture, and one of the three core elements of OSHA’s Safe & Sound framework for creating a sustainable safety and health program.

What Does Management Leadership Mean

OSHA defines management leadership as it relates to safety as a commitment from the top to implement a safety and health program and use it to drive continuous improvement. Best-in-class safety cultures have mature, well-functioning systems that integrate leadership and employee engagement into standard operating practices. When leadership commitment is sincere and supported by visible action, workers understand that safety and health are not side priorities; they are core to business success.

Strong leadership turns safety from a compliance obligation into a shared operational value. It gives the safety and health program direction, provides the resources needed to make progress, and sets expectations for managers, supervisors, and workers. Just as important, it demonstrates care. Effective safety leaders show workers that their well-being matters, concerns will be heard, and safety decisions will be backed by action. Without leadership commitment, even well-designed programs can become inconsistent, underfunded, or disconnected from daily work.

Make Safety a Core Organizational Value

Management leadership starts with making worker safety and health a core organizational value. This includes developing a clear policy statement signed by top management and communicated across the organization. The message should be simple and direct: Protecting workers is as important as productivity, quality, profitability, customer satisfaction, and other business priorities.

Safety and health should be integrated into planning, budgeting, purchasing, contractor selection, facility design, staffing, scheduling, and operational changes. When leaders consistently consider risk before work begins, safety becomes part of how the organization operates, not a separate activity reviewed only after an incident.

Define Goals and Assign Accountability

Specific program goals are important, so everyone understands what the organization is working to improve. These goals should focus on prevention-oriented actions, not just injury or illness rates. Examples include completing hazard assessments, closing corrective actions on time, increasing near-miss reporting, improving training completion, reducing exposure risks, or strengthening emergency preparedness.

Goals are only effective when they are supported by clear ownership. Leaders should assign responsibilities, establish timeframes, provide authority to act, and review progress regularly. Managers and supervisors should be expected to integrate safety into everyday work planning, and workers should be encouraged to report concerns and participate in solutions without fear of retaliation.

Communicating Commitment through Visible Action

Safety leadership must be demonstrated through day-to-day behaviors. Effective safety leaders are visible, credible, consistent, and engaged. They care about people, communicate clearly, listen actively, make informed decisions, and reinforce expectations through their own actions. They also recognize that culture is shaped by what leaders tolerate, prioritize, fund, measure, and reward.

Visibility matters. Executives, managers, and supervisors should be present in operations, ask questions, listen to workers, participate in safety walk-arounds, and model the same safe behaviors they expect from others. Leadership credibility depends on consistency; workers notice whether leaders follow procedures, use required protective equipment, correct hazards, and respond constructively when safety concerns are raised.

Allocate the Resources Needed to Succeed

Organizations need to provide the people, time, training, equipment, tools, technology, and budget needed to implement and maintain the safety and health program. That includes giving workers time to participate in inspections, training, incident reviews, safety meetings, and improvement activities. It also means ensuring corrective actions are funded and completed, hazards are controlled, and supervisors have the support and resources needed to manage safety performance effectively.

Recognize Contributions and Expect Performance

Effective safety leaders also create the conditions for employee engagement. They invite input, encourage reporting, and make it clear that workers have an active role in identifying hazards and improving controls. This matters, because the people closest to the work often have the best understanding of what can go wrong and what practical solutions will work.

Leaders can reinforce positive safety behaviors by recognizing workers and teams that identify hazards, contribute ideas, complete corrective actions, mentor others, or support emergency readiness. Recognition should be tied to meaningful actions that prevent harm, not simply low injury rates.

At the same time, leaders must expect performance. Safety responsibilities should be built into roles, job expectations, contractor requirements, and performance discussions. Managers and supervisors should be held accountable for supporting the program, addressing hazards, communicating expectations, and following through on commitments. Leaders should reinforce expectations by opening meetings with safety and health updates, reviewing outstanding action items, discussing trends and leading indicators, and following up on concerns raised by workers.

Practical Actions for Management Leaders

• Develop or refresh a written safety and health policy signed by top management.
• Communicate safety expectations to workers, contractors, staffing agencies, vendors, and visitors.
• Begin leadership meetings with safety and health updates, open action items, and leading indicators.
• Participate in safety walk-arounds, hazard reviews, and worker discussions.
• Listen to worker concerns, encourage reporting, and respond without blame or retaliation.
• Set realistic, measurable goals focused on hazard prevention and continuous improvement.
• Assign responsibilities, deadlines, and resources for program activities and corrective actions.
• Integrate safety and health into planning, budgeting, procurement, staffing, and operational decisions.
• Recognize workers and teams for proactive safety contributions.
• Model safe behaviors and follow the same procedures expected of workers.

Leadership Sets the Standard

A robust safety and health program depends on leadership that is visible, consistent, engaged, and accountable. When leaders communicate that safety matters, provide the resources to act, listen to workers, recognize meaningful contributions, and make safety part of everyday decisions, they create the conditions for hazards to be found and fixed before they cause harm. Management leadership gives the safety and health program the authority, momentum, and credibility it needs to succeed, and it helps build the safety culture needed to sustain results over time.

KTL will be a featured presenter and exhibitor at the 2026 Chicagoland Safety, Health & Environmental Conference in Naperville, Illinois, September 14-16, 2026. The Conference provides timely and relevant environmental management, safety, health, professional development and OSHA/EPA compliance training to EHS professionals, business owners, facility managers, plant managers, supervisors, safety committee members, human resources managers, municipalities, and others who have safety, health, and environmental management and compliance responsibilities.

KTL Sessions

Session T05: EHS Data Management: A DIY Approach | Tuesday, September 15, 8:30-10:00 am CT
Building an EHS compliance management system doesn’t have to be complicated or expensive—not when most companies already have the software they need. Learn how to build data management tools to collect, track, and report EHS compliance information using the latest Microsoft 365 and Power Platform apps. This session will walk through key features and functionality of an EHS compliance management system, discuss the importance of a plan-do-check-act development approach, and provide tips to ensure successful development and implementation. See working examples and hear directly from EHS and IT experts on how to leverage familiar Microsoft tools to cost-effectively elevate EHS processes and management systems and drive ongoing compliance.

Session W18: Framework for Creating a Best-in-Class Safety Culture | Wednesday, September 16, 1:15-2:45 pm CT
High-profile incidents in industries from energy to manufacturing demonstrate that safety compliance alone is not enough—organizational culture determines whether safety systems thrive or fail. Consistent with OSHA’s Recommended Practices for Safety and Health Programs and ISO 45001, this session outlines a practical framework for building a best-in-class safety culture focused on ten key attributes: leadership, values, goals and initiatives, organization and structure, employee engagement, resource allocation, systems and standards, metrics and reporting, continual learning, and verification and auditing. This presentation will help professionals create a Safety Culture Action Plan that moves the organization beyond short-term initiatives toward sustainable cultural excellence through proven implementation techniques. Participants will gain actionable insights to strengthen their own safety cultures, improve safety outcomes, reduce incidents, and create organizational resilience.

Stop by KTL’s booth (#101) to talk more about your safety, health, and environmental needs. We look forward to connecting with you in Naperville!