Functionality: What does it do?

Training is a key component of maintaining ongoing compliance—whether with regulatory requirements, supply chain mandates, or internal policies. Having a system that records employee training is critical, especially to ensure policies, procedures, and work instructions are followed. KTL’s training tracking systems allow for the centralized implementation, management, tracking, scheduling, assignment, and analysis of organizational training efforts.

Benefits: Why do you need it?

A web-based training tracking system can help:

• Outline and document training requirements.
• Create training plans and workflows for scheduling training and assignments by job title and function.
• Ensure competency through online quizzes.
• Log and track training and certifications completed—including classes, required reading, online education, CEUs, and outside certifications.
• Track certification/training expirations and send notifications to complete training.
• Create individual dashboards and training reports for managers and employees, improving accessibility of training expectations and records.
• Demonstrate compliance with regulatory requirements for training.

Technology Used

• SharePoint to store the training data
• PowerApps to record and manage course information
• Power Automate for email notifications

KTL is excited to be joining the 2023 Midwest Environmental Compliance Conference (MECC) in Overland Park, Kansas, September 26-27, 20023 as a featured presenter. MECC takes a fresh, regional approach to the increasingly difficult task of environmental compliance, permitting, enforcement, and other critical environmental issues that impact Midwest facilities and institutions.

KTL’s presentions are part of the workshop’s technical agenda:

What is an energy audit—and why you should do one
September 26, 2023 | 12:30 pm | Coulter Wood, CEM, CPEA, Senior Consultant

Want to reach your sustainability goals, improve your energy efficiency, and save money? Learn what an energy audit is, how it can help you better understand your energy usage and issues, and how you can leverage your audit to identify opportunities to create energy efficiencies and reduce your carbon footprint.

The big secret: you already have the software you need to manage EHS programs
September 27, 2023 | 9:35 am | Joe Tell, Principal

Implementing software to manage EHS compliance sounds expensive, but it doesn’t have to be—not when most companies already have the software they need. See how to leverage the Microsoft Power Platform® to elevate EHS and effectively manage compliance documentation and data.

Safe + Sound Week

At the most basic level, a root cause is the fundamental reason—or the highest-level cause—for the occurrence of a problem, incident, or event. Getting to the root cause of any problem is important not just for resolving the issue at hand, but for identifying underlying issues to ensure that similar problems do not recur in the future. Importantly, finding the root cause should not focus on placing blame on an individual but rather on finding the systemic cause of an incident. This starts with a process called the root cause analysis (RCA).

What Is the Root Cause Analysis (RCA)?

RCA is a method of problem-solving used to identify the underlying (i.e., root) cause(s) of a problem or incident. It is a systematic process based on the basic idea that effective management requires more than merely putting out fires and treating symptoms. RCA seeks to identify and address the true, underlying concerns that contribute to a problem or event.

Why is this important? If you just treat the symptoms of the problem, that alleviates them for the short term, but it does nothing to prevent the problem from coming back again. Lasting solutions address the underlying factors—the root cause(s)— that create the problem in the first place. Targeting corrective measures at the identified root causes, subsequently, is the best way to alleviate risk and ensure that similar problems do not occur in the future.

Best Practice

The Occupational Safety and Health Administration (OSHA) encourages organizations to conduct RCA following any incident or near miss at a facility. RCA can be broken down into a simple six-step process, as outlined below.

Step 1: Identify and Clearly Describe the Problem

The first step is to understand and document the problem/issue/incident that occurred. This might involve interviewing key staff, reviewing security footage, investigating the site, etc. to get an accurate account of the issue. Safety-related incidents might require an immediate fix or prompt action before carrying out the complete RCA. This is always the priority.

Some problems are easier to define than others based on what happened and the extent of the issue. When defining and describing the problem, it is important to be as descriptive as possible, as this will aid in future steps to identify the root cause(s).

Step 2: Identify Possible Causes…Why?

There are several methods for identifying possible root causes, including the following:

• 5 Why Method simply involves asking the question “Why” enough times (i.e., five times) to get past all the symptoms of a problem and down to the underlying root cause of the issue.
• Event Analysis builds a detailed timeline around the target event and analyzes it to see where things went wrong. This method is best for one-time incidents versus a pattern of behavior.
• Change Analysis helps determine the root cause of a general shift in behavior. It looks at all changes in the organization that preceded the change in safety behavior/metrics; defines the relationship between possible causes and effects; and categorizes each organizational change as either unrelated, correlated, contributing, or root cause.
• Fishbone or Ishikawa Diagram is a visual cause-and-effect diagram that encourages you to think of every possible cause by examining a wide variety of aspects of the incident.

Step 3: Identify Root Cause(s)

Where does your questioning lead you? Is there one root cause or a series of root causes that emerge? The root cause(s) of most incidents ultimately fall under one of the following:

• Poor management/supervision
• Lack of company culture
• Insufficient work environment
• Improper training

Again, identifying the root cause should not focus on placing blame on an individual but rather on finding the systemic cause of an incident.

Step 4: Corrective and/or Preventive Action Taken

Based on the identified root causes, it then becomes possible for the facility to determine what corrective and/or prevention actions (CAPAs) can be taken to fix the problem and, just as important, prevent it from recurring in the future.

Step 5: Analyze Effectiveness

The effectiveness of whatever action is taken in step 4 needs to be evaluated to determine whether it will resolve the root cause. If not, another CAPA should be explored, implemented, and analyzed to assess its impact on the issue/problem. If it is a root cause, it should help to resolve the issue and you should move on to step 6 below.

Step 6: Update Procedures, as necessary

As CAPAs are implemented, once they prove effective, related policies and procedures must be updated to reflect any changes made. This step ensures the outcomes of the RCA will be integrated into operations and used to prevent similar incidents from happening in the future.

Benefits of RCA

Following these steps will help ensure a thorough investigation that identifies root cause(s) versus just symptoms is conducted. It further ensures that any changes related to the root cause are integrated into the organization to prevent similar events from happening again. In the end, the RCA can help:

• Reduce the risk of injury and/or death to workers and community members.
• Avoid unnecessary costs resulting from business interruption; emergency response and cleanup; increased regulation, audits, and inspections; and OSHA fines.
• Improve public trust by maintaining an incident-free record.
• More effectively control hazards, improve process reliability, increase revenues, decrease production costs, lower maintenance costs, and lower insurance premiums.

Safe + Sound Week

Most companies have health and safety policies and procedures in place to help ensure the safety and well-being of their employees. At a minimum, it is important to verify implementation of required safety programs at all locations. As a best practice, implementing a safety management system (SMS) provides companies with the opportunity to better manage, control, and improve health and safety performance.

SMS Basics

An SMS is the organizing framework that enables companies to achieve and sustain their operational and safety objectives through a process of continuous improvement. The SMS is designed to identify and manage safety risks through an organized set of policies, procedures, practices, and resources that guide the enterprise and its activities to maximize business value. The SMS addresses:

• What is done and why.
• How it is done and by whom.
• How well it is being done.
• How it is maintained and reviewed.
• How it can be improved.

Each company’s SMS reflects its unique safety culture, vision, and values. To be effective and valuable, the SMS must be tailored and focused on how it can enhance the business and safety performance of the organization. It must also be:

• Useful to people in the operations.
• Intuitive—organized the way operations people think.
• Flexible—making use of methods and tools as they are developed and documented.
• Valuable from the outset—addressing the most critical risks and processes.
• A means to better align safety with operational quality, environmental concerns, and overall business operations.

SMS Development

An effective SMS requires senior management commitment and guidance, coupled with employee engagement. Importantly, the SMS involves a continual cycle of planning, implementing, reviewing, and improving the way in which safety obligations and objectives are met. In its simplest form, this involves implementing the Plan, Do, Check, Act/Adjust (P-D-C-A) cycle for continuous improvement.

There are some basic steps to creating a SMS:

• Invest the time to understand the current scope of operations, functional departments, compliance requirements, governance structure, etc. across the entire organization, not just siloed departments.
• Conduct a gap assessment to evaluate the current (“as-is”) condition of any formal or informal SMS against the desired (“to-be”) condition (e.g., ISO 45001, ANSI Z10).
• Create a development and implementation plan outlining tasks and resources required to close any identified gaps and achieve those objectives.
  • Determine key components of the SMS required to achieve business objectives.
  • Identify common elements to be standardized and incorporated into the SMS (e.g., policies, procedures, processes, metrics, training).
  • Determine what information technology can support and streamline the SMS.
• Provide relevant training to all interested parties to truly operationalize the SMS across the organization.

SMS Standards

ISO 45001 and ANSI Z10 both offer widely recognized frameworks for creating an effective SMS—one that helps companies to:

• Identify and control health and safety risks.
• Reduce the potential for accidents.
• Aid in legal compliance.
• Achieve greater consistency and reliability.
• Improve overall performance.

The ISO 45001 and ANSI Z10 standards both contain elements that are designed to be compatible with the structures of ISO 9001 and ISO 14001, allowing organizations to more easily align their SMS with other existing management systems (e.g., environmental, quality, food safety, security). An aligned SMS helps companies to achieve improved and more reliable safety performance, while adding measurable business value.

Certification

Companies can become certified to each of the standards discussed above. Certification has a number of benefits, including the following:

• Meet customer or supply chain requirements.
• Use outside drivers to maintain management system process discipline (e.g., periodic risk assessment, document management, compliance evaluation, internal audits, management review).
• Take advantage of third-party assessment and recommendations.
• Improve standing with regulatory agencies (e.g., OSHA, state programs).
• Demonstrate the application of industry best practice in the event of incidents/accidents requiring defense of practices.

However, if there is no market or other business driver, certification can lead to unnecessary additional cost and effort regarding management system development. Certification in itself does not mean improved performance—management system structure, operation, and management commitment determine that.

Bringing Value to the Organization

The connection between the SMS and compliance is vital in avoiding recurring compliance issues and in reducing variation in safety performance. In fact, reliable and effective regulatory compliance is commonly an outcome of consistent and reliable implementation of a management system. Beyond that, there are a number of business reasons for implementing an SMS:

• Establishes a common documented framework to achieve more consistent implementation of compliance policies and processes.
• Provides clear methods and processes to identify, prioritize risks, and communicate risks to employees and management—then allocate the resources to mitigate them.
• Allows for development of meaningful objectives to drive ongoing improvements in health and safety performance.
• Empowers individual facilities and departments to take responsibility for processes and compliance performance without waiting to be told “what” and “how”.
• Enables better collaboration and communication across a distributed company with many locations.
• Provides tracking information and reporting on common safety activities and performance metrics across the company.
• Builds company know-how, captures/retains institutional knowledge, and creates consistent processes and procedures that support personnel changes (e.g., transfers, promotions, retirements, new employees) without causing disruption or gaps.
• Allows for more consistent oversight and governance, yielding higher predictability and reliability.

Safe + Sound Week

According to the Occupational Safety and Health Administration (OSHA), thousands of workers become sick from occupational heat exposure each year—and some of these cases turn fatal. Hazardous heat exposure can occur indoors or outdoors, during any season, and to anyone. This is why it is important that all employers take steps to reduce heat exposure and protect employee health and safety.

Heat-Related Illnesses and Injuries

Exposure to extreme heat (i.e., heat stress) can result in occupational illnesses and injuries, including heat stroke, heat exhaustion, heat cramps, or heat rashes. Heat can also increase the risk of ancillary injuries due to sweaty palms, fogged-up safety glasses, dizziness, and even deterioration of fine motor performance. Burns may also occur from accidental contact with hot surfaces or steam.

Heat stroke is the most serious heat-related disorder and should be considered a medical emergency. It occurs when the body becomes unable to control its own temperature. Workers suffering from heat stroke may experience dizziness or unconsciousness, disorientation, slurred speech, chills, and headache. If you or another employee are suffering from heat stroke, exhaustion, or fainting, alert a supervisor immediately and call 911.

Risk Factors

Workers who are exposed to extreme heat or work in hot environments may be at greater risk of heat stress. This includes both outdoor workers and workers in hot environments (e.g., firefighters, cooks/chefs, bakery workers, farmers, construction workers, miners, boiler room workers, factory workers, and others). Occupational risk factors for heat illness include heavy physical activity, lack of acclimatization, and wearing clothing that holds in body heat. In addition, individuals who may be particularly susceptible to heat-related illness include those who are 65 years of age or older, are overweight, have heart disease or high blood pressure, or take medications that may be affected by extreme heat.

Planning and Prevention

Heat-related illness is often preventable, especially with management commitment to providing the most effective controls. An effective heat-related illness prevention program should be developed and incorporated into every company’s broader safety and health program. Important elements to consider when creating the heat plan include the following:

• Who will provide oversight and heat monitoring throughout the workday as conditions change?
• How will new and/or temporary workers gradually develop heat tolerance (i.e., acclimatization)?
• How will the employer ensure first aid is adequate?
• What is the protocol for summoning medical assistance?
• What engineering controls and administrative work practices will be used to reduce heat stress?
• How will heat stress be measured?
• How will the company respond when the National Weather Service issues a heat advisory or heat warning?
• What training will be provided to workers and supervisors?

Controls

Workplace heat stress can be reduced using several methods. Engineering controls involve changing the design of the workplace in ways that reduce exposure to heat. This might include increasing air velocity; using reflective or heat-absorbing barriers; or reducing steam leaks, wet floors, and humidity. Administrative (workplace) practices involve changes to tasks, schedules, and behaviors to reduce heat stress. These may include:

• Limiting time in the heat and/or increasing recovery time spent in a cool area.
• Increasing the number of workers per task.
• Requiring workers to conduct self-monitoring.
• Creating work groups (i.e., workers, a qualified healthcare provider, and a safety manager) to make decisions on self-monitoring options and standard operating procedures.
• Providing adequate amounts of cool, potable water near the work area and encouraging workers to drink often.
• Using a heat alert program whenever the weather service forecasts a heat wave.

Acclimatization— the process of building heat tolerance—is a particularly important control. 50% to 70% of outdoor fatalities occur in the first few days of working in warm or hot environments because the body needs to build a tolerance to the heat gradually over time. Employers should ensure that new workers, temporary workers, and workers who have been on vacation are acclimatized before they work in a hot environment by gradually increasing workers’ time in hot conditions over 7 to 14 days.

Finally, employers should provide training to workers so they understand what heat stress is, how it affects their health and safety, and how it can be prevented. Training should include:

• Signs and symptoms of heat-related illnesses and administra­tion of first aid.
• Causes of heat-related illnesses and steps to reduce the risk.
• Proper care and use of heat-protective clothing and equipment and the added heat load caused by exertion, clothing, and per­sonal protective equipment.
• Effects of other factors (drugs, alcohol, obesity, etc.) on tolerance to occupational heat stress.
• Acclimatization process.
• Reporting symptoms or signs of heat-related illness.
• Procedures for responding to symptoms of possible heat-related illness and for contacting emergency medical ser­vices.

Personal Accountability

To avoid becoming a victim of heat stress of any type, wear light-colored, breathable clothing, such as cotton. Gradually build up to more strenuous work. Schedule more breaks on days with extreme heat and humidity. Drink water! Lots of water! Avoid soda, energy drinks, alcohol, or any other drinks that have high amounts of caffeine and sugar in them. And ALWAYS monitor yourself and others who are at risk for heat stress in hot and /or humid conditions.

More resources:

• https://www.cdc.gov/niosh/topics/heatstress/default.html
• https://www.osha.gov/heat-exposure

Safe + Sound Week

In the post-COVID world, working remotely and alone has become much more common. In many industries, particular attention needs to be paid to these lone workers to ensure appropriate practices and procedures are in place to keep them safe.

What Is a Lone Worker?

Lone workers are people who perform their jobs alone—without someone else present and without any supervision. Lone workers cannot be heard or seen by another individual while working. They may work in more remote locations with limited emergency response or perform jobs during nonstandard work hours. Lone workers may also work in the same building or area as others but out of viewing or hearing distance.

Workplace Safety Hazards

A workplace safety hazard is anything that could potentially cause harm or damage to people, property, or equipment. The most common safety hazard for all workers, including lone workers, is slips, trips and falls. Another common safety hazard that lone workers face is from machinery and equipment, which can injure or trap the worker. 

To avoid workplace safety hazards, there are certain conditions where lone work is not recommended and/or prohibited, including the following conditions:

• From height
• With electricity or in confined spaces
• During severe weather conditions
• Around avalanche risks
• Near chemical exposure that could incapacitate a worker
• When respirators or air monitoring is required
• Using hazardous equipment (e.g., chainsaws, firearms)
• Where the potential for violence is present

Planning and Preparation

The Occupational Safety and Health Administration (OSHA) does not have a standard for employees working alone; however, there are several standards that apply to specific lone-work situations (e.g., emergency response, interior structural firefighting). OSHA further recommends that employers develop emergency procedures and provide “a wireless electronic notification device and/or cellphone to those employees.”

As best practice, any company with lone workers should develop and implement a lone worker safety program with specific practices and procedures to minimize the risk of injury. This includes the following:

1. Identify, assess, and mitigate work hazards. It is important to identify safety hazards in any work environment but particularly for lone workers who must navigate hazardous situations alone. Each hazard’s level of risk must be assessed. Once this assessment is complete, strategies can then be implemented to remove existing dangers to the extent possible, prioritizing the highest risk hazards. Hazard mitigation should consider physical modifications, safety education and training, and communication to help ensure workplace injuries and incidents occur less frequently.
2. Create a lone worker policy. This policy should establish the organization’s rules and practices for working alone. Generally, a lone worker safety policy should include:
   • Contact information and location of all lone workers
   • General safety guidance
   • Roles and responsibilities
   • Safety procedures and processes, including predetermined safety check-ins and stop-work guidance
   • Methods of communication and available backups (e.g., cell phone, GPS devices, and mobile apps)
   • Emergency procedures and contacts
   • Lone worker training and continuous education
3. Monitor lone workers. Lone workers must be monitored, whether through regular manual check-ins or automated monitoring systems. Both allow the employer to confirm the worker’s safety and well-being. If a worker misses a check-in, an automated system can immediately request help and employ tools such as GPS location tracking to provide necessary assistance. 

Don’t forget about your lone workers. They play an important role and special provisions need to be taken to ensure they are monitored and protected.

Safe + Sound Week

When it comes to the characteristics of an excellent safety culture, communication is at the top. It is vital that all levels of management (senior, middle, supervisory) communicate their commitment to safety clearly to workers. It is equally important that workers feel empowered to discuss their safety concerns.

Having a safety culture where workers do not feel like they can speak up at work when it comes to their safety can present significant threats to workers and the overall well-being of the company. A high percentage of workplace injuries occur when a worker witnesses unsafe behaviors or conditions but chooses not to say anything. Those injuries are 100% preventable. However, it requires creating a culture of transparency and openness that encourages staff to look out for each other and speak up when concerns arise—and a culture where team members are not afraid of voicing their safety concerns, no matter how big or how small they may be.

How to Effectively Speak Safety

Workers may be reluctant to accept safety advice for many reasons:

• They don’t like being told what to do.
• They don’t believe they are in danger.
• They perceive safety conversations/assistance as punishment or aggression.

The challenge is to have productive conversations about safety despite these barriers, considering not only what you say but how you say it. For many, this does not necessarily come naturally, which is why effective safety conversations should be taught and practiced.

These tips can help make speaking about safety easier:

• Take a persuasive approach versus a punitive one. Safety conversations shouldn’t be about catching someone doing something wrong. The goal should be safety, not punishment.
• Demonstrate care and concern. It is much more meaningful to show concern for the personal safety of individuals than to reinforce compliance with rules.
• Speak the worker’s language. Think about who you are speaking to and what is important to them. Delivering a safety message to senior management will differ than communicating with field staff.
• Focus on specifics. Avoid expressing judgment or disapproval. When addressing a specific safety behavior or situation, limit comments to that rather than making general statements.
• Listen. Good communication goes both ways. A respectful conversation will involve both expressing yourself and listening to the other person.
• Don’t be intimidated. The fear of a negative reaction is common, particularly when a less experienced person must deliver advice to someone more senior. Remember, no one is immune to safety concerns.
• Lead by example and encourage others to do the same. It is one thing to say that safety is a priority; it is another thing to show that it is.

Sometimes, relying on those around us to help notice and communicate when something isn’t right can provide the best form of safety protection—because no one is immune to safety concerns, safety errors, distraction, or complacency. Improving an organization’s overall safety culture and the atmosphere around safety conversations can make it easier to both give and receive advice in a constructive way and, best-case scenario, save lives.

Functionality: What does it do?

Depending on the breadth and location(s) of a company’s operations, managing permits and their associated requirements and due dates without a centralized system in place can present significant challenges: How many permits does your operating system have–and what are the associated requirements? Who is responsible? Are there key/critical dates? How do you manage all that information and verify compliance? KTL’s permit tracking tool provides a central repository to track, manage, and communicate permit activity tracking. 

Benefits: Why do you need it?

A web-based permit tracking system can help:

• Catalog and track permits and associated requirements and timeframes in one database.
• Manage change information.
• Store critical documents for easy access and effective record control.
• Send and receive notifications of permits about to expire.
• Coordinate and communicate with project contractors.
• Establish accountability and a standardized approach for reporting, monitoring, and performance measurement.
• Improve permit compliance assurance reliability, efficiency, and consistency.

Technology Used

• Microsoft Power Automate: send/receive notifications
• Canvas PowerApp: catalog permits, trigger notifications, create user interface
• SharePoint Lists: tracking changes, store data
• SharePoint Document Library: store attachments, permits, contracts, etc.

The threat of terrorism against our food supply is as real today as it ever has been. Whether it’s an attack on the products themselves, such as product tampering or sabotage, or a cyberattack against a company’s internet infrastructure, it can be harmful and costly if not recognized in advance. Plans should be in place to not only respond to such an attack but also to prevent it. ~ Rod Wheeler, NSF.org

National Security Memorandum

On November 10, 2022, President Joe Biden signed National Security Memorandum-16 (NSM-16) to strengthen the security and resilience of U.S. food and agriculture. This critical sector has continued to face increasing deliberate and naturally occurring threats to security and resilience, including intentional adulteration (IA), catastrophic events (e.g., pandemics that impact critical infrastructure), consequences of climate change, and cyber- and technology-related vulnerabilities.

NSM-16 replaces Homeland Security Presidential Directive 9 (Defense of United States Agriculture and Food – HSPD-9) and outlines the Administration’s guidance to:

1. Identify and assess the threats of greatest consequence. This includes redefining how chemical, biological, radiological, and nuclear threats are defined; focusing on increased cyber threats and climate change impacts; and enhancing threat and risk assessments by mandating a continuous process to assess and mitigate risks and vulnerabilities.
2. Strengthen partnerships to enhance the resilience of the workforce, who are typically the first line of response, and coordinate our government to act more efficiently and effectively. Essential critical infrastructure workers need guidance to work safely, while supporting operations during high-consequence incidents.
3. Enhance preparedness and response by training partners on how to prepare for and respond to threats, increasing testing and diagnostic surge capacity, and standardizing diagnostic and reporting tools to facilitate timely information sharing.

Ongoing Security Actions

NSM-16 builds upon ongoing actions by the Administration to strengthen the resilience of the U.S. food and agriculture supply chains.

• U.S. Department of Agriculture (USDA) considers defense of the food and agriculture sector critical. USDA’s Food Safety and Inspection Service (FSIS), Animal and Plant Health Inspection Service (APHIS), and National Institute of Food and Agriculture (NIFA) have launched numerous programs to protect these sectors, including FSIS working to help industry partners develop effective food defense plans.
• U.S. Department of Homeland Security (DHS) Office of Health Security Health, Food, and Agriculture Resilience (OHS/HFAR) directorate is also working to help safeguard the American food supply against catastrophic incidents by bringing a national security perspective to the food and agriculture sector.  In recent years, OHS/HFAR has engaged directly with partners to perform risk assessments, develop strategic guidance, and design and deliver tailored exercises to better prepare for, respond to, and recover from catastrophic events.
• U.S. Food and Drug Administration (FDA) is engaging with federal; state, local, tribal, and territorial (SLTT) governments; the private sector; and academia on the following activities:
  • Conduct of vulnerability assessments
  • Risk mitigation analysis
  • Federal risk mitigation strategy
  • Strengthening existing efforts for information sharing procedures
  • Research and development

Roles of Food Safety and Food Defense

According to USDA-FSIS, to prevent, protect against, mitigate, respond to, and recover from threats and hazards of greatest risk to the food supply, preparedness efforts must encompass food safety and food defense.

Food safety provides for the protection of food products from unintentional contamination. Food defense involves the protection of food products from intentional contamination or adulteration (e.g., biological, chemical, physical, or radiological) that causes harm to public health or disrupts the economy in other ways.

The anticipated outcome of combined food safety and food defense efforts is food security. Food security exists when all people, at all times, have physical, social and economic access to sufficient, safe and nutritious food which meets their dietary needs and food preferences for an active and healthy life (United Nations Food and Agriculture Organization (FAO)).

Your Role: Food Defense Plan

Food defense involves putting security measures in place to reduce the chances of someone intentionally contaminating the food supply. FDA’s Food Safety Modernization Act (FSMA) rule on Mitigation Strategies to Protect Food Against Intentional Adulteration (IA) establishes requirements for industry to play an active role in improving the nation’s food security and resilience. This rule requires covered facilities to prepare and implement food defense plans.

The food defense plan incorporates four major elements:

• The vulnerability assessment identifies those areas in the process that pose the greatest IA risks. Each step in the facility’s process should be evaluated for the following:
  • Potential severity and scale of the impact on the public.
  • Physical access to the product.
  • Ability to successfully alter/contaminate the product.
• Facilities must develop and implement mitigation/preventive strategies at each step in the process to address vulnerabilities and minimize the risks of IA.
• A system must be put in place to ensure implementation of mitigation strategies and to effectively manage the following:
  • Monitoring mitigation strategies, including frequency.
  • Corrective action response.
  • Verification activities.
• Appropriate recordkeeping must be maintained for food defense monitoring, corrective actions, and verification, and key personnel must receive appropriate training.

The safety and security of our country’s food products requires developing, implementing, and enforcing policies and programs to support strong food defense. And it requires continually involving all employees in these food defense and security efforts to create a robust food safety culture. The threats to our nation’s food supply—and to those companies who work in the food supply chain—will continue. Taking an active role in controlling what you can and proactively managing your organization’s food defense efforts can play a significant role in securing the food supply chain.

According to the Occupational Safety and Health Administration (OSHA), successful safety and health programs can proactively identify and manage workplace hazards before they cause injury or illness, improving sustainability and the bottom line. An organization’s safety culture is ultimately reflected in the way that safety is managed in the workplace, and having a strong safety and health program can help create:

• Fewer accidents, losses, and disruptions by preventing workplace injuries and illnesses.
• Engaged employees and improved morale.
• Increased productivity and enhanced overall business operations.
• Lower workers’ compensation and insurance claims.
• Improved compliance with OSHA regulations.
• Improved reputation to attract new customers and employees and retain existing ones.
• Better brand and shareholder value that tie to social responsibility.

H&S Observations

The National Safety Council (NSC) cites that more than 4,400 preventable workplace deaths and 4.26 million injuries occurred in 2021. Raising public awareness about workplace safety can significantly decrease the number of preventable injuries and deaths. Every June, NSC observes National Safety Month to do just this by encouraging employers and individuals alike to be safety role models.

Much like NSC, OSHA created Safe + Sound Week (August 7-13, 2023) as a year-round campaign to encourage America’s workplaces to commit to workplace safety and health by starting a health and safety program, energizing an existing one, or recognizing health and safety successes.

Taking the Pledge

This year, both NSC and OSHA are encouraging companies to reaffirm their commitments to safety and health by taking a pledge:

Safe + Sound pledge: I pledge to make safety a core workplace value. Everyone has the right to a safe and healthy workplace, and I will work to ensure everyone goes home safe and sound every day. My workplace will be taking action to improve our safety and health program during Safe + Sound Week 2023.

NSC SafeAtWork pledge: I commit to:

• Actively help my employer improve our safety programs.  
• Report hazards promptly and suggest solutions.  
• Be a good safety role model for my friends and family, even off the job.  

Core Elements of Workplace Health and Safety

OSHA reiterates that the core elements of a workplace health and safety program include the following elements:

• Management leadership. Management must provide the leadership, vision, and resources needed to implement an effective safety and health program.
• Worker participation. Engaging workers at all levels in establishing, implementing, evaluating, and improving safety and health in the workplace creates buy-in.
• Systematic approach to finding and fixing hazards. Finding and fixing hazards in the workplace is an ongoing process to better identify and control sources of potential injuries or illnesses.

KTL’s Series on Investing in Safety

Throughout OSHA’s Safe + Sound Week (August 7-13, 2023), KTL will be featuring a series of articles and posts on our blog and social media (i.e., Facebook, LinkedIn, Twitter) reinforcing these concepts from OSHA and NSC and discussing why businesses should invest in safety. Topics will include the following:

• Speaking safety
• Lone worker safety
• Heat stress
• Safety Management Systems (SMS)
• Root cause analysis

Watch for these articles! For more information on what your organization can do to participate and promote a strong safety culture, visit the websites for OSHA Safe + Sound Week and NSC National Safety Month.