Building a Safety Program When There Isn't One

You show up on your first day. You ask where the safety manual is. Someone points to a binder on a shelf that hasn't been opened since 2016. Half the pages are from a different company. The emergency action plan lists phone numbers that are disconnected.

I've been in this situation more than once. It's more common than people think, especially at mid-size manufacturers and companies that grew fast without building the infrastructure to match. The good news is it's fixable. The bad news is it takes discipline and sequencing matters.

Here's how I approach it.

Week One: Look and Listen

Don't write anything yet. Walk the floor. Watch how people work. Look at the housekeeping, the PPE usage, the machine guarding, the chemical storage. Talk to the supervisors. Talk to the operators. Ask what worries them.

You'll learn more in your first week of observation than in a month of reading whatever documentation exists. And you'll build credibility by showing that you care about what's actually happening, not just what's supposed to be happening.

The Order That Matters

You can't do everything at once. Here's the sequence I've found works best:

1. Emergency Action Plan. If something goes wrong today — a fire, a chemical release, a serious injury — what happens? Who calls 911? Where do people go? Where's the first aid kit? This is your floor. If it doesn't exist, you're exposed right now, not next quarter. Build it first.
2. Hazard Communication. Are SDSs available and current? Do people know where they are? Can they access them? This is low-hanging fruit from a compliance standpoint and it protects people from chemical exposures immediately.
3. Lockout/Tagout. If you've got machinery, you need LOTO procedures. People die from energy isolation failures. This isn't optional and it can't wait.
4. Incident reporting and investigation. Set up a system — even a simple form and a spreadsheet — so that when things happen, they get documented. You can't fix what you don't track. And OSHA 300 logs need to be maintained regardless.
5. Training documentation. Start tracking who's been trained on what and when. Even if you haven't built all the training yet, get the tracking system in place. When OSHA shows up, they'll ask for training records before they ask for anything else.

After those five are in place, you can start building out the full program: confined space, fall protection, hearing conservation, respiratory protection, hot work, crane safety — whatever applies to your operation. But those first five cover your immediate exposure.

Don't Overcomplicate It

I've seen new EHS managers walk in and immediately try to implement ISO 45001, build a behavioral observation program, and roll out a near-miss reporting app. All good ideas. All wrong for day one.

Start with the basics. Make them work. Get buy-in from the floor. Then build. A simple program that people actually follow beats a sophisticated one that sits in a binder.

Get Leadership to Show Up

None of this works without visible support from the top. The plant manager needs to attend a safety meeting. The operations director needs to walk the floor with you. Not because it's a photo op, but because people watch what leadership does. If leadership treats safety as a checkbox, everyone else will too.

I've found that the single most effective thing a leader can do is stop a production line for a safety concern. It only has to happen once. After that, everyone knows it's real.