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1. Managing EHS
compliance
Globally
June 2014

2. AGENDA
1. Adopting an EHS global system
2. Main stakes
3. Condition for success
4. Organizational models
5. Expected Return On Investment

3. A GOBAL
EHS SYSTEM
_
Why?

4. MITIGATE
Risks

5. SAVE
Money

6. CORPORATE
Image

8. ANTICIPATE
Future changes

9. CORPORATE
≠
LOCAL

10. C O R P O R A T E
G l o b a l v i s i b i l i t y
L O C A L
C o m p l y w i t h l o c a l
r e g u l a t i o n
NEEDS
Differ at corporate level vs local level
Exhaustive, Detailed information
Focus on action plans
Avoid hazards
Worldwide overview
Identify main issues
Strategic decisions

11. MULTI-LOCAL
Vs International

12. USA
Federal vs State

13. USA
• Federal hazardous waste rules set requirements based on
the amount of waste generated; less than 100kg per
month = Conditionally Exempt Small Quantity
Generator; between 100kg and 1,000kg = Small
Quantity Generator; greater than 1,000kg per month =
Large Quantity Generator;
• In Kansas, however, a Conditionally Exempt Small
Quantity Generator = less than 25kg per month; so a
facility that generates 50kg per month in Kansas is a
Small Quantity Generator, but a facility that generates
50kg per month in Illinois is a Conditionally Exempt Small
Quantity Generator; this is important because CESQG
have a reduced regulatory burden compared to SQG;
Example 1

14. USA
• USTs: federal regulations are listed at 40 CFR 280
(and 40 CFR 112 for petroleum products); certain
states are “delegated” the authority to enforce their
own standards so companies in those states just
have to comply with the one set of rules; other
states, such as New Jersey, have yet to receive such
authority so a facility with USTs in New Jersey must
meet both the federal set of rules and the state set
of rules; while they are VERY similar, they do
contain minor reporting and recordkeeping
differences;
Example 2

15. USA
• California is the only state in the US with an
ergonomic H&S standard; no federal OSHA
requirements;
• California has more stringent Permissible
Exposure Limits (PELs) for certain chemicals;
for example, acetone is a common solvent; CA’s
PEL is 500 parts per million (ppm), while federal
OSHA’s PEL is 1,000 ppm.
Example 3

16. AUSTRALIA
EHS is regulated almost exclusively by the states and
territories

17. AUSTRALIA
• Even if there is a trend towards harmonization :
Model work Health and Safety Act &
Commonwealth Work Health and Safety Act
• Not all states already follow federal rules right
now and specificities are numerous
Few details

18. GERMANY
National Regulations in HS completed by a set of
technical rules

19. GERMANY
HEALTH AND SAFETY
• General Regulations (federal) are completed by a set of
technical rules : recommendations and suggestions for
the compliance with regulatory requirements. They are
NOT legal rules or standards by nature BUT :
– Specificity of German Statutory Accident
Prevention Regulations: some, through apparently
technical rules, have a dual legal character; UVV or
BGV which are issued by insurers and professional
associations
Few details

20. GERMANY
ENVIRONMENT
• Central regulations at National level but enforcement is
done at Federal as well as Länder level.
Few details

21. CHINA
TUNISIA
Need local experts
to access information
(not all publications
are published online
by governments)

22. CHINA
• China is a centralized political system,
• However, the principal regulations are not necessarily
be found at the national level (as in France, as opposed
to federal system such as the US),
• Other important regulations can be found at regional
and municipal level, NOT ONLY regarding
environmental questions BUT ALSO in the field of HS.
• This especially concerns industrially developed areas like
Beijing, Shanghai and Guangdong.
Few details

23. FRANCE
ICPE

24. FRANCE
• A particularity of the French legal system is that
if you have an installation or site which is
classified as “ICPE” (installation classée pour
l’environnement), a special set of rules that
applies (e.g. Chapter V of the French
Environmental Code] .
Few details

25. FRANCE
Regulation hierarchy
1. Constitution / International and EU treaty;
2. Directives & Community regulations;
3. Ordinance, Law, decree
4. Circular, norms, internal rules, etc.
Few details

26. BRAZIL
Some of the strictest environmental legislation in the world

27. CONDITIONS
FOR
SUCCESS

28. LOCAL EXPERTS

29. LOCAL EXPERTS
• No language barrier
• EHS regulatory framework knowledge
• Access to local information
To be hired

31. PROJECT MANAGEMENT
• Share objectives between sites and corporate
• Define Human, Money and Technology Resources
• Adaptation of the project according to company
structure
– Multi sites / Multi activities
– Industrials vs Facilities management / Building
• Adopt a standardized structure / information type /
reporting to be shared between Corporate and Sites
– Audit protocol in English
• Project animation
Conditions for success

32. ORGANISATIONAL
MODELS

33. IMPLEMENTATION
• Centralized structure
– HQ controls EHS
• Flexible approach
– Strong rules & standards at corporate level, authority at local level
• Regional structure
– Delegation of authority at local level
Different structures

34. IMPLEMENTATION
• EHS legal register definition
– Sites pilots
– Process of Rollout
• Legal watch
– Frequency
– Format of information
• Compliance assessment
– Existing data
– Assistance
• Action plan implementation
Internal resources vs outsourcing

35. IMPLEMENTATION
• EHS legal register definition
• Legal watch
• Compliance assessment
• Action plan implementation
Internal resources vs outsourcing
I N T E R N A L OUTSOURCED

36. TREND
• Secure regulatory processes
• Save costs
• Save time, focus on action
• Speed up roll out
Towards outsourcing the international
regulatory expertise

37. ROI

38. CULTURE OF COMPLIANCE
• Reduce risks globally
• Optimize costs linked to risk management
• Save time
• Benchmark countries and implement strategy
accordingly
Why reinforcing culture of compliance globally
is important?

40. In a few words
June 2014

41. RED ON LINE
Partner to provide HSE Solutions, Worldwide
CONSULTING
CONTENT SOFTWARE
EHS Legal
Monitoring and
Compliance
Solution

42. RED ON LINE
Partner to provide HSE Solutions, Worldwide
45
9Countries already
covered
9 offices in
4 continents
“AAA partner”
TRC Corporation Listed
Company NYSE

43. UTAS
Malaysia

44. OIL RIGS
Nigeria

45. ARIANE
Kourou

46. METHODOLOGY
For a 100% personalized service
1. EHS
Legal Register production
Site visit to identify
EHS impacts
Questionnaires and
Interviews
Integration of specific
documents
Personalized legal register
production – Software set up
2. EHS
Legal Monitoring
Weekly * news alerts
Quarterly* update of
the Regulatory Registe
Regulatory Assistance
3. EHS
Compliance Assessment
Site audits
Audits reports
Compliance status
recorded in the software
Action plan can be initiated
by the site or co-initiated
with our engineers
Cross countries & cross site
reporting is available
* Frequency may be different in some countries

47. « not only a software »

48. RED ON LINE
What’s next
1. Site visit questionnaire document query
2. Legal Register available after 3 weeks
3. Transfer of Existing Compliance status in HSE-Compliance
4. Training
5. EHS Legal Monitoring

49. RED ON LINE
100% of our clients succeed

50. THANK YOU
Offered by Red-on-line :
• Choose your country factsheets
• Ask us 3 legal questions
services