New EHS Director in 90 Days: What to Fix Before Changing the Strategy

A new EHS director often inherits a polished strategy, a full dashboard, and a workforce that has already heard several versions of the same promise. The first leadership test is not whether the director can announce a better plan. It is whether the director can identify which decisions, controls, and routines are producing the risk people actually face.

The safest transition follows a deliberate sequence. Listen before redesigning, verify conditions in the field, clarify who owns the hard decisions, and then narrow the strategy to a few priorities that operations can execute. This 90-day plan is built for that transition.

What does a new EHS director need to understand before changing direction?

A new EHS director needs to understand how risk moves through the organization, not only how the management system is documented. That means comparing policy with permits, risk assessments with work sequences, escalation rules with actual decisions, and reported events with what supervisors believe is safe to disclose.

ISO 45001, published in 2018, expects leadership, worker participation, operational planning, and continual improvement to work as one system. A certificate does not prove that those elements are connected during a shutdown, a production shortfall, or a contractor handover. The director must inspect the connection.

Andreza Araujo's book The Illusion of Compliance frames the problem clearly. Formal completion can coexist with weak control when the organization rewards evidence of activity instead of evidence that exposure fell. That distinction should shape the first 90 days.

First week: Which signals reveal the real safety system?

During the first week, avoid a presentation tour that turns every meeting into advocacy for the current structure. Ask leaders, supervisors, contractors, and worker representatives what can stop work, what gets escalated, and what remains unresolved after the report is closed.

Review a small evidence set before requesting a large data extract. Select recent serious near misses, overdue high-risk actions, critical-control checks, permit deviations, and cases in which production pressure changed the plan. The quality of the explanation matters more than the volume of records.

Spend time where work changes shape. A control that looks effective in a procedure may be bypassed at a line break, during a night shift, or when a contractor arrives late. Capture those transition points because they expose weak ownership faster than a headquarters meeting does.

Days 8 to 30: How should the director verify critical exposure?

Build a short critical-risk map with operations, maintenance, engineering, and frontline representatives. Do not make it a catalog of every hazard. Identify the credible events that could cause a fatality or life-changing injury, the barriers intended to prevent them, and the evidence that each barrier is available and used.

For each priority exposure, ask four questions. Who owns the control? What failure would be visible before harm? How often is the control checked by a competent person? What happens when the check fails? If the answer depends on a general statement such as “everyone is responsible,” the ownership is not clear enough.

Use the existing risk register cleanup process to remove stale risks and duplicate actions, then compare the result with the field map. The purpose is not to make the register prettier. It is to expose where the organization has accepted risk without naming the decision-maker.

Days 31 to 45: Which decisions and accountabilities must become explicit?

By the second month, the director should publish a decision-rights map for high-risk work. It should show who may accept residual risk, who must stop a job, who owns a failed barrier, and which issues move directly to the executive team.

This is where many transitions lose credibility. The director asks for stronger accountability while leaving budget authority, staffing decisions, and operational priorities untouched. Accountability without authority becomes a reporting ritual, which is why the map must include the resources required to keep controls reliable.

Andreza's Antifragile Leadership connects leadership strength with the capacity to use disruption as information. In practical terms, a failed control should trigger a better decision process, not a search for a convenient individual to blame. James Reason's work on latent failures supports the same discipline by directing attention toward conditions that make errors more likely.

Days 46 to 60: What should the director change in field leadership?

Replace ceremonial visibility with a repeatable field routine. Executives and line leaders should visit the same critical activities, ask about the same barriers, and record what they will change. The routine becomes useful when leaders return to the location and verify whether the promised change occurred.

A good field conversation is specific enough to reveal work conditions. Ask what changed since the plan was approved, which control is hardest to maintain, what would make the task safer, and who can resolve the obstacle today. These questions create evidence about system quality without turning the visit into an inspection theater.

Compare the new routine with the field-risk observation approach. The goal is not to increase the number of walks. It is to ensure that field presence changes priorities, removes barriers, and makes escalation visible.

Days 61 to 75: How can a new EHS director protect reporting and dissent?

People judge a new director by what happens after bad news arrives. When a worker raises a concern, the response should separate the quality of the information from the convenience of the timing. A concern that interrupts production may still be the most valuable safety input of the week.

Review whether supervisors receive recognition for surfacing weak controls, whether contractors can report without going through the person who controls their next assignment, and whether action owners close the loop with the person who raised the concern. A reporting channel without visible follow-up teaches silence.

Use the distinction between climate, psychological safety, and speak-up metrics to avoid treating a single survey score as proof of trust. The director needs behavioral evidence, including what people say when the information is inconvenient.

Days 76 to 90: Which strategy should the director commit to?

At the end of the third month, reduce the strategy to a few priorities that have an owner, a decision path, a resource requirement, and a review date. A useful plan might focus on isolation quality, contractor interface, critical-control verification, and escalation discipline, but the priorities should come from the diagnosis rather than from a generic annual calendar.

Use one leading measure and one outcome measure for each priority. For example, critical-control verification can be paired with the number of failed checks corrected within the agreed time. This keeps the dashboard connected to action. The limits of lagging indicators are a reminder that a low injury count cannot validate barriers that have never been tested.

Andreza's work across more than 250 cultural transformation projects and 30+ countries reinforces the value of local ownership inside a coherent direction. During her PepsiCo South America tenure, the accident ratio fell 50% in six months. The transferable lesson is not a number to copy. It is the discipline of connecting leadership cadence, operating choices, and measurable risk reduction.

What mistakes should a new EHS director avoid?

The first mistake is changing the vocabulary before understanding the work. New labels can create the appearance of movement while leaving weak controls untouched. The second is treating the dashboard as neutral when its definitions reward reporting volume instead of barrier reliability. The third is launching training before fixing the work design that makes the required behavior difficult.

Another mistake is keeping every inherited priority alive. A director who adds new initiatives without stopping obsolete ones increases the load on the same supervisors who already struggle to maintain critical controls. Strategic clarity requires subtraction, especially when the organization is recovering from an incident or a prolonged period of production pressure.

What should the EHS director review after the 90-day transition?

The 90-day review should ask whether the organization now makes safer decisions when conditions change. Examine failed controls, escalated concerns, overdue actions, field commitments, and the quality of executive responses. Then ask workers and supervisors whether the new routines help them control risk or simply create more records.

A strong transition leaves the organization with fewer ambiguous priorities and more visible ownership. It also gives the director a defensible basis for the next investment decision, because the strategy is connected to observed exposure rather than inherited assumptions.

How can a new EHS director make the first 90 days credible?

Make the transition credible by showing what was heard, what was verified, what changed, and who owns the remaining decisions. The new strategy should be the consequence of that evidence. It should not be a replacement document created before anyone has tested the old one in the field.

Across 25+ years leading EHS at multinationals, Andreza Araujo has treated visible felt leadership as an operating discipline rather than a communication style. That is the practical standard for a new director. People should be able to see leadership in the controls that are repaired, the risks that are escalated, and the decisions that no longer depend on silence.