In Part III of this series, Affygility Solutions is pleased to discuss the process of defining and composing your Company’s OHSAS 18001 and Potent Compound Safety policy. Now I know some of you will be tempted to take the easy route and go online, find some other company’s policy, and tweak-it to make it your own – but don’t do it –start from a blank sheet of paper with fresh ideas.
When establishing your Company’s policy, the actual process of getting consensus on each of the words in the policy is more valuable than the policy itself. When composing an OHSAS and potent compound safety policy that will stand the test of time, every word takes on a meaning of its own. Questions will arise about should this be a “should” or “shall”?, should this be a “we will” or “it is our intent”? You should also plan that writing of the policy will take much longer than you would believe – in some cases, it can take 6 months or longer to get consensus from all the major stakeholders.
Key points to follow when composing your OHSAS and potent compound safety policy are:
- OHSAS and potent compound safety policies should be a “principle-based” document, not a list of rules.
- Aim for composing a document that can fit on one-sheet of paper and can be framed. As you can expect, writing this concise is hard work and time consuming.
- Involve all major stakeholders such as industrial hygiene, environmental, occupational toxicology, facilities, operations, research, clinical, legal, human resources, and the group responsible for interfacing with contract manufacturers.
- Plan that this document will eventually be endorsed by top management at your facility.
- As indicated in the OHSAS 18001 text, include a commitment to prevention of injury and ill health, and continual improvement. Continual improvement is one of the core concepts behind any management system and it is essential that it is in the policy.
- Include a commitment to comply with applicable legal requirements.
- Include a commitments for prior assessment of risks, ongoing assessment of risks, and for placing a priority on engineering controls to control exposures.
- Include a commitment for communicating hazard information.
- Ensure that the policy provides a framework for setting and reviewing objectives.
Additionally, as part of the Company’s management system, the OHSAS and potent compound safety policy will need to be periodically reviewed, communicated to internal and external parties, and steps taken to ensure that it remains relevant.
Don’t underestimate the importance of creating an OHSAS and potent compound safety policy. It is a process that helps create buy-in for the whole process going forward.