Within a Safety Management System, a procedure is required for both internal and external communications. Many third party Safety Management System certifications only requires a procedures and allows the organization to the degree of openness and disclosure of information. Whenever a decision has been made in terms of disclosure, the decision process must be recorded.
COMMUNICATION
For internal communications within the organization, the procedure needs to describe how communication is done among the various levels of the organization. For external communications, it has to describe how external communications are received, how they are documented, and document the response provided.
Defining External Communications: Written or electronic correspondence, complaints or regulatory inquiries about employee safety and health practices, telephone conversations and oral discussions or meetings with anyone not directly employed by xxxx company (includes regulatory agencies, special interest groups, and neighbors).
Defining Internal Communications: Written or electronic correspondence, telephone conversations and oral discussions or meetings with anyone directly employed by xxxx company.
One method of managing both internal and external communications is to treat them similar in nature. In other words, the documented process should be similar for both. A communication log simplifies this documented process. Below is an example of a header from a Communication Log:
While maintaining such a log in an Excel spreadsheet, it is possible to insert pdf, email communication, etc., in the ‘Topic of Communication’ and ‘Response’ columns. If for some reason that is not feasible, simply create a folder on a shared drive called ‘Communication Log Library’ to house these pdf’s and email communications. Having such documents easily accessible is an efficient method to showcase to anyone who wishes to follow up on the communication log event number.
Another tip is to have a review and revision table on the bottom of the log in order to provide evidence of when the log was updated to add a communication event. Be specific in detail on the revision table as you are in the log itself. At a minimum, the log should be reviewed annually to make sure all communication events have been recorded. Below is an example of a review/revision table.
In conclusion, a written communication procedure along with documented communication log will suffice for any Safety Management System third party certification or corporate mandate. This is especially true when you maintain a library of correspondence for both internal and external events.