Brussels • Washington Feb/Mar 2014

RegulatingEndocrine Disrupting Chemicals

P3Enhesa global

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Japan: Rising demand for global EHS services日本市場で高まるグローバルEHS 遵法支援サー ビスへのニーズP21

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Feb/Mar 3 Cover: The precautionary principle

Regulating endocrine disrupting chemicals

10 Asia-PacificRegulatoryOutlook2014An update at EHS&S Management Roundtable

12 GlobalregulatorymonitoringP12 Europe & Africa/ P31 Asia Pacific/ P35 Americas

13 A Cleaner Air For All Air Quality in Europe

16 GlobalEHSRiskBlogTjeerd Hendel-Blackford discusses unusual legal obligations

18 EHSHelplineEHS in Buenos Aires

21 RisingDemandforEHSServicesEnhesa is meeting the needs of its clients in Japan

27 ErgonomicsThe impact on Health and Safety

32 ProductHelplineCosmetics in China

34 SpecialFlash Sneak peak at Enhesa’s upcoming Special Edition Flash

36 AuditTipDocument preparation - the key to a successful audit

42 EventsWebinars and Conferences

43 ABraveNewWorldEnhesa’s New Public Website

3Regulating endocrine disrupting chemicals

27Ergonomics: the impact at work

21Rising demand for EHS services

13Air Quality in Europe

© Enhesa Flash Feb/Mar 2014

Is the precautionary principle still thedrivingforce?

Regulating endocrine disrupting chemicals

Enhesa Flash Feb/Mar 2014 4

These are the types of questions that are being considered by many companies in light of significant consumer, government and industry concern for EDC. In 2010, Enhesa organized a webinar to further delve into this topic. At the time, North America and the European Union were taking the global upper hand in attempt-ing to classify, assess and regulate potentially harmful EDC. The purpose of this article is to build on the same topic, but provide insight on some of the more recent regulatory and policy developments with regard to EDC.

Definition and ClassificationThe Organisation for Economic Co-opera-

tion and Development (OECD) has adopted the following working definition for an endocrine disrupting chemical (EDC) and a potential EDC as agreed upon by an OECD Workshop hosted by the European Union and World Health Orga-

nization in Weybridge, UK in December 1996:- ‘An endocrine disrupting chemical (EDC) is an exogenous substance that causes adverse health effects in an intact organism, or its prog-eny, consequent to changes in endocrine func-tion.’- ‘A potential endocrine disrupting chemical (EDC) is a substance that possesses properties that might be expected to lead to endocrine disruption in an intact organism.’

While a clear definition has been devel-oped and accepted on the international level, it is less clear which substances can actually be classified to fit into this definition. In Febru-ary 2013, the United Nations Environment Pro-gramme (UNEP) and the World Health Orga-nization (WHO) published a new report to add clarity on the classification of EDC. The State of the Science of Endocrine Disrupting Chemicals 2012 report provides an update of the scientif-

Are you aware of what substances are classified as endocrine disrupting chemicals (EDC)? Do you carry out any operations involving EDC?

Most persistent organic pesticides are considered to be endocrine disrupting

The aim of the report is to address concerns about the potential adverse health effects of chemicals on humans and wildlife.

Enhesa Flash Feb/Mar 2014 5

ic knowledge with an aim to address concerns about the potential adverse health effects of chemicals on humans and wildlife.

In general, previous assessments of EDCs were primarily focused on POPs, but this report has broadened the scope to include less per-

sistent and less bioaccumulative organic chem-icals, such as current-use pesticides, plasticiz-ers, pharmaceuticals, natural hormones, and phytoestrogens, as well as metals.

The report organizes endocrine disrupting chemicals into eleven broad classes based on their physical-chemical characteristics or origin/application areas. Examples of the classes in-clude: Persistent Organic Pollutants (POPs): PCDDs/PCDFs, PCBs, HCB, Mirex, Endosul-fan, etc.; Plasticizers and Other Additives in Materials and Goods: Phthalate esters (DEHP, BBP, DBP, DiNP), Triclocarban, Butylated hy-droxyanisole, etc.; Polycyclic Aromatic Chem-icals (PACs) including PAHs: Benzo(a)pyrene, Pyrene, Anthracene, etc..

Bisphenol ABisphenol A has been generally accepted

as a known EDC. As a result, countries are rely-ing on the precautionary principle to take legis-lative action. Bisphenol A is used primarily as a

formulant in the manufacture of polycarbonate plastic and epoxy resins. Polycarbonates have wide application in consumer products (e.g. re-peat-use polycarbonate containers), in medical devices, glazing applications, film and the elec-tronics industry, while epoxy resins are used in protective coatings, structural composites, and electrical laminates and as adhesives and seal-ants.

In Canada, the classification and assess-ment process of the Chemicals Management Plan established that bisphenol A meets the criteria to be designated as “toxic” according to the Canadian Environmental Protection Act, 1999 (CEPA) toxic and was added to the List of Toxic Substances in October 2010. As a result, a risk management approach for the substanc-es has been proposed to implement several measures. The first risk management measure took effect on 20 June 2011 with the adoption of the Canada Consumer Product Safety Act 2010, c.21. As a result, manufacturing, import-ing, advertising or selling of polycarbonate baby bottles that contain bisphenol A is prohibited in order to reduce newborn and infant exposure to this substance.

In April 2012, the second risk management measure was adopted. Any owner or operator of a facility that manufactures bisphenol A (BPA), or uses BPA or a mixture containing BPA, in quantities exceeding 100 kg in a calendar year, and that discharges effluents containing BPA,

Polycarbonate baby bottles that contain bisphenol A are prohibited in Canada.

Enhesa Flash Feb/Mar 2014 6

must prepare and implement a pollution pre-vention plan in relation to the release of BPA in effluents. Pollution prevention planning is a sys-tematic, comprehensive method of identifying and implementing pollution prevention options to minimize or avoid the creation of pollutants or waste.

Measures restricting the use of bisphenol A are also being adopted in Asia. Beginning 1 July 2012, businesses in South Korea have been prohibited from manufacturing, importing or selling infant feeding bottles containing BPA. The Korea Food and Drug Administration ref-erenced the movements to prohibit the use of BPA in infant feeding bottles in other countries, such as the EU and Canada, as a reason for making the amendments.

In addition to the adoption of restrictive measures, some jurisdictions are conducting re-search on alternatives. On 11 December 2012, the Maine Department of Environmental Protec-tion (DEP) released a private report detailing a Bisphenol-A Alternatives Analysis. The report focused on the use of bisphenol A in children’s products. It indicated that polyethylene is a pre-ferred alternative to packaging that uses a lining made from bisphenol A due to its inexpensive-ness and the fact that there are no health impli-cations from its use. DEP has already banned the use of bisphenol A in baby bottles and sippy

cups. It has proposed a rule that would ban the use of bisphenol A in containers for formula and food for babies and toddlers.

EPA ActionLegislation in 1996 resulted in the creation

of the Endocrine Disruptor Screening Program (EDSP). The EDSP was established under Section 408(p) of the Federal Food, Drug, and Cosmetic Act (FFDCA), which requires EPA to develop a chemical screening program using appropriate validated test systems and other information to determine whether certain sub-stance may have hormonal effects. The EDSP

uses a two-tiered approach. Tier 1 screening identifies substances that have the potential to interact with the endocrine system (in particu-lar, the estrogen, androgen, or thyroid hormone systems). Substances that do have the poten-tial to interact with these hormone systems may proceed to Tier 2 screening, which is designed to identify any adverse endocrine-related ef-fects caused by the substance.

The EPA issued final policies and proce-dures in June 2013 for requiring Tier 1 screening

In addition to the adoption of restrictive measures, some jurisdictions are conducting research on alternatives.

Endocrine disruptors like BPA have been linked to birth defects in frogs, fish and humans alike.

Companies that manufacture or import commonly used pesticides, pharmaceuticals and plasticizers could now be subject to an EPA testing order.

Enhesa Flash Feb/Mar 2014 7

under the EDSP to supplement those already in place. Section 1457 of the Safe Drinking Water Act (SDWA) authorizes EPA to issues EDSP test orders to manufacturers and importers of chemi-

cals that may be found in sources of drinking wa-ter and to which a substantial population may be exposed. These chemicals may include industrial and pesticide chemicals, ingredients in pharma-ceuticals and personal care products, and degradates.

The final policies and procedures are intended to ensure that the is-suance of test orders is focused on obtaining data from companies that might be expected to contribute to a chemical’s presence in drinking wa-ter, rather than tied to the use of the chemical in any given market. They seek to ensure that the policies and procedures for SDWA chemicals are consistent with policies and proce-dures under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug and Cosmetic Act (FFDCA) as much as possible.

Also in June 2013, the final second list pro-vides 109 chemicals for Tier 1 screening was published. It includes pesticides, three phar-maceuticals (erythromycin, nitroglycerin, and quinoline), and many chemicals used in indus-trial processes such as plasticizers. Companies that are involved with manufacture or import of active ingredients of any listed chemical and that hold an active EPA registration under FIFRA

may be subject to an EPA testing order. The EPA may provide for testing of these chemicals if it determines that a substantial population is exposed to these substances.

European Union initiativesThe European Union has also been taking

strides to better classify, assess and regulate EDC. Regulation (EC) No 1907/2006 concern-ing the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) was ad-opted on 1 June 2007. The most relevant part of REACH for the purposes of implementing measures for EDC is the authorization compo-nent. Substances of very high concern (SVHC) are those that can cause cancer, mutations or problems with reproduction (CMRs), or that ac-cumulate in human bodies and the environment (i.e. persistent, bioaccumulative and toxic or

very persistent and very bioaccumulative), as well as other chemicals which are of ‘equivalent concern’. These will be put on the Candidate List. These substances will have to obtain au-thorisation which is specific to a particular use or application. Also, within this group of sub-stances, some will be subject to stricter condi-tions in order to obtain an authorisation by de-cision of the European Commission.

Another common type of EDC is perfluorinated chemicals, which are found in food packaging and in the non-stick coating of cookware. Phthalates and BPA are also commonly found in food packaging.

Enhesa Flash Feb/Mar 2014 8

More recently, the European Parliament Resolution of 14 March 2013 on the protection of public health from endocrine disrupters and the discussion paper of the European Com-mission on “Possible elements for criteria for identification of endocrine disrupters” are the first steps for potential future regulatory mea-sures to be adopted specifically on endocrine disrupters.

The Resolution states that, even though there is no scientific evidence, endocrine dis-rupters are considered as a possible cause for a growing frequency of hormone-related disor-ders in humans. It therefore advocates that ‘the absence of precise knowledge, including final proof of causal links, should not prevent health protection measures to be taken in line with the precautionary principle, keeping in mind the principle of proportionality’.

Therefore, the EP is asking for regulatory mea-sures addressing endocrine disrupters based on the precautionary principle. The Resolution’s pro-

posed measures include, for example:-the introduction of ‘endocrine disrupter’ as

a regulatory class for purposes of chemical clas-sification, with different categories based on the strength of evidence; and

-a review by the Commission of all relevant legislation in order to identify whether they pro-vide sufficient protection to humans, in particular pregnant women, babies, children and teenag-ers and, if necessary, amend existing legislation or propose regulatory changes (including haz-ard and risk assessments) by 1 June 2015.

AsiaAs seen in the example of bisphenol A re-

strictions in South Korea, companies in Asia are now starting to focus on EDC. As another example, the China Ministry of Environmental Protection published the 12th Five-Year Plan on Chemical Environmental Risk Prevention and Control on 20 February 2013. This Plan indi-cates that some toxic chemicals phased-out or restricted by developed countries are still being mass produced and used in China. It also indi-cates that many chemicals have been detect-ed in some rivers, lakes and offshore waters, wildlife and human bodies. Some regions have seen their levels of persistent organic pollutants and endocrine disruptors rise above the inter-national level. The Plan of 20 February 2013 was developed in order to establish a more

Enhesa Flash Feb/Mar 2014 9

comprehensive chemical management system in terms of minimizing environmental risks.

58 types of chemicals are listed as priority risk prevention and control chemicals, including several known EDC, such as bisphenol A. China will take measures to control the environmental risks posed by these chemicals, including im-posing pollutant release and reporting require-ments; strengthening emergency response measures; and imposing stricter monitoring and supervision requirements.

Business impactsWhen considering the business impacts re-

sulting from the development of legislation re-garding EDC, one needs to first consider that these substances are in a unique position. De-spite the scientific uncertainty, measures are still being implemented to significantly restrict their use in products operations. On one side, consumer concern is acting as a market force driving industry to take the initiative and make adjustment in products and operations. On the other hand, several governments, such as Can-ada, are favouring the use of the precaution-ary principle in developing specific measures. In this regard, such jurisdictions are discount-ing the lack of certainty and implementing new restrictive measures in light of the potential for these substances to be endocrine disrupting.

As a result of the development of new re-strictions or requirements regarding EDC, a company could expect a potential administra-tive burden or financial burden. The adminis-trative burden results from such requirements reporting under the Canadian Chemicals Man-agement Plan and obtained authorisation un-der REACH in the European Union. Financial burden is much broader. Any required alteration or cessation of operations involving EDC will cause a company to incur financial loses. These requirements could include changes in raw ma-terial selection to avoid and reduce EDC, in pro-duction process to minimise releases of EDC, in

design specifications to avoid and reduce the presence of EDC in products being sold and the conditions for purchase of components and parts that contain EDC. These measures could also result in a provision to necessitate waste-water treatment to avoid or reduce discharge or to implement measures to address worker exposure to EDC.

ConclusionIn this regard, what can you do to avoid

incurring an administrative or financial burden for any operations involving EDC? In the first instance, it should be a priority to review the substances with high concern of endocrine dis-ruption and assess if any of these are used in operations or products. It would advantageous to record information on or develop a man-agement plan for any of the activities involving these substances (i.e. regarding use of EDC in production of manufactured items or release of EDC in wastewater discharges). Identifying products at risk and attempting to find alterna-tives to the use of EDC as far as possible would also be a key step in preparing for the imple-mentation of any new stringent legislation be-ing adopted. Bottom line, affected companies should not wait for government action to begin implementing measures to restrict or eliminate use of EDC. Invoking the idea of the precau-tionary principle is the way forward for dealing with EDC.

Meghan White Business Development Manager

Enhesa Flash Feb/Mar 2014 10

On 21 November 2013, Enhesa’s Asia-Pacific reg-ulatory specialists presented an update on environ-mental and occupational safety and health policy and regulatory developments in Asia to the Envi-ronmental, Health, Safety and Sustainability Man-agement Roundtable meeting at the National Press Club in Washington. Enhesa regulatory specialists Qijun Lí, Meng Du, Min Kho, Sansanee Dhana-sarnsombat and Riaz Zaman provided a timely up-date of recent regulatory and policy developments impacting companies operating in China, Taiwan, Hong Kong, South Korea, Japan, Thailand and oth-er Southeast Asian countries, as well as India and

Australia respectively in a one-hour presentation ti-tled “Asia-Pacific Regulatory Outlook for 2014.”Topics addressed ranged from the new enforcement guidelines being implemented in China in line with the policies being rolled out by incoming President Xi Jinping, and new air quality standards being intro-duced in 2014 in Hong Kong, to the recent adoption and roll-out in Korea of a new chemical regulatory regime similar in most aspects to the EU’s REACH Regulation, to new greenhouse gas reduction tar-gets just announced in Japan (and Australia’s po-tential retreat from its most recently instituted GHG emissions trading scheme), to a variety of imminent

Asia-Pacific RegulatoryOutlook for2014

Enhesa presents an update on Asia EHS policy and regulatory trends at EHS&S Management Roundtable

The EHS&S Roundtable is a voluntary coalition of senior environmental executives from companies dedicated to improving the efficiency, effectiveness, consistency and quality of EHS programs industry-wide.

Enhesa Flash Feb/Mar 2014 11

laws and regulations to control industrial and prod-uct environmental impacts in the ASEAN countries and India.The update was followed by a lively discussion of what Roundtable members can expect in the com-ing year with respect to their operations and markets

in the region. Members of the EHS&S Roundtable present included representatives of companies from the broadest range of activities, including aero-space, automotive, chemicals, electronics, energy, food and beverage, medical devices, oil and gas, personal care products, pharmaceuticals, pulp and paper and forestry products, retailing, transporta-tion and others.Other topics addressed at this biannual meeting in-cluded, amongst others: a discussion of safety and sustainability initiatives in China, risk-based supply chain management, green chemistry applications in the pharmaceuticals industry, an update on ISO 14001 and an overview of US OSHA programs for the coming two and a half years. Joining Enhesa at the podium were a number of illustrious speakers, including Susan Briggs, Convenor of ISO Technical Committee 207; Marina Moses of the National Acad-emy of Sciences, Lynn Scarlett of the Nature Conser-vancy and Former Deputy Secretary of the Interior; and Ed Foulke, Former Assistant Secretary for Labor and currently partner at Fisher & Phillips, LLP.Formed in January 1988, the EHSS Roundtable is a voluntary coalition of senior environmental exec-utives from companies dedicated to improving the efficiency, effectiveness, consistency and quality of

environmental, health and safety programs indus-try-wide. Beginning in the mid 90s, focus has also included sustainability, energy, business manage-ment and social responsibility. The group, which is non-advocacy and cross-industry in nature, meets twice a year to discuss mutual problems and share solutions. Membership is by invitation and is open to the two senior most officers of EH&S (energy, se-curity, and sustainable development also) of fortune 1000 firms. Membership is limited in number so as to build and foster a network of senior EH&S of-ficers who can readily and candidly communicate with each other.Tom Davis, formerly Director, Global EH&S Exter-nal Affairs of AT&T is the Executive Director of the Roundtable. Mr. Davis is also an environmental consultant specializing in creating sustainable rela-tionships between the corporate and environmental NGO worlds. The current Chairman of the Round-table is Jim Thomas, Vice President, Sustainability and EH&S, Petco. For further information regarding Enhesa and the ser-vices in which they provide, visit www.enhesa.com, or visit marketing@enhesa.com

Paul Beatley Director, Enhesa SA

12

Europe-AfricaBahrain

• Supreme Council for the Environment amends decision concerning management of hazardous chemicals 29-Nov-2013 [53647]

Belgium• BRUSSELS REGION: Small office buildings only need an energy performance (EPB) certificate by 2017

07-Nov-2013 [39163]• FEDERAL: Ban on the use of “Total Clear” detergent repealed 22-Nov-2013 [51144]• FEDERAL: Clarifications adopted concerning the transport of dangerous goods by air 17-Oct-2013 [11062]• FEDERAL: Requirements modernised concerning collective protective equipment 07-Oct-2013 [53066]• FLEMISH REGION: Extensive changes adopted to environmental laws to bring them into line with the EU

and best-practice 21-Oct-2013 [45517]• FLEMISH REGION: More stringent rainwater discharge and collection requirements adopted 08-Oct-2013

[49972]• FLEMISH REGION: Support introduced for useful renewable heat, residual heat and biomethane injection

20-Nov-2013 [53487]• WALLONIA: Final allocation of greenhouse gas emission allowances for 2013-2020 published 17-Oct-

2013 [53491]• WALLONIA: Grant of green certificates to installations producing electricity from bioliquids subject to

sustainability criteria 03-Oct-2013 [53115]• WALLONIA: New framework for aviation activities under the EU Emissions Trading Scheme (ETS) entered

into force 24-Oct-2013 [53118]• WALLONIA: Strengthening of the use of best available techniques in environmental permits in line with the

IED 24-Oct-2013 [52596]

Bulgaria• Additional building energy certification requirements 22-Nov-2013 [53788]• Biowaste quality, record keeping, reporting and labelling obligations introduced 22-Oct-2013 [53083]• Lists of Military Products and Dual Use Products Subject to Export Controls reissued 24-Oct-2013 [46535]• Obligations of EEE manufacturers, importers and distributors and of WEEE management operators

increased, in line with WEEE2 Directive 19-Nov-2013 [53537]• Owners of waste landfills can use an escrow account for providing financial guarantees securing closure

and post-closure activities 27-Dec-2013 [54312]

Enhesa globalmonitoringDuring November and December 2013, many new EHS and product regulations were adopted that could directly impact your business. Here we present a selection of the regulatory developments per country. For more details on any of these developments, and to learn more about or subscribe to one of Enhesa’s different Regulatory Monitoring services, please contact us at info@enhesa.com. For further information visit www.enhesa.com

Continued on page 15

Enhesa Flash Feb/Mar 2014 13

A cleaner air forall?Air Quality in EuropeThere have been some significant recent steps at the European level to try to ensure air quality across the continent. 2013 was publicised by the European Commission as being the “Year of the Air” in Europe. During the EU’s annual Green week held from 4 to 7 June 2013, the European Commission announced that it was working on several proposals which should improve air quality in Europe. The measures could help reduce the number of premature deaths and people with asthma. Also, the improvement of the air in Europe should have a positive effect on ecosystems (less acid rain and less damage of eco-systems by reducing nitrogen pollution).In December 2013, the European Commission published its programme entitled “A Clean Air Pro-gramme for Europe.” This programme consists of both long- and short term measures, but the long-term measures are particularly interesting.

Enhesa Flash Feb/Mar 2014 14

A proposed directive regarding emissions of combustion plants will introduce emission limit values for medium combustion plants between 1-50 megawatt (MW).

Air Quality in EuropeThe first proposed measure is that the European Commission will ratify the amendment to the 1999 Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution to Abate Acidification, Euthrophication and Ground-level Ozone (the so-called Gothenburg Protocol). As a result of the rat-ification, the European Commission will align EU legislation (Directive 2001/81/EC on national emis-sion ceilings for certain atmospheric pollutants, the so-called NEC Directive) with the revised emission ceilings for nitrogen oxide (NOx), ammonia (NH3), sulphur dioxide (SO2) and volatile organic com-pounds other than methane (NMVOCs) and newly introduced ceilings for particulate matter (PM2.5) to be met by 2020. In addition, the emission limits for methane (CH4) as currently laid down in the NEC Directive will be amended, in order to reduce the number of greenhouse gas emissions. This should contribute to keeping global warming below 2°C.

Even though the proposed amendments to the NEC-Di-rective are mostly directed to Member States companies might be impacted as they will be required to reduce their greenhouse gas emissions so that Member States meet their national emissions ceil-ings. More specifically, Member States will need to reduce SO2, NOx, NMVOCs, NH3, PM2,5 and CH4 emissions by 33% by 2030 compared to the 2005

levels. Especially, companies in the agricultural sec-tor emitting NH3, but also CH4 and companies in the maritime sector emitting NOx, PM2,5 and SO2 will be impacted by the proposed amendments to the NEC Directive.

Emissions of combustion plantsAnother proposed Directive, which will impact com-panies more, is the proposed Directive on the lim-itation of emissions of certain pollutants into the air from medium combustion plants. This Directive will introduce emission limit values for medium com-

bustion plants between 1 and 50 MegaWatt (MW). These plants are, in particular, used in large build-ings and in industrial facilities in general. This should not only avoid the possible trade-offs between air quality and increased biomass use, but also help reducing emissions of PM, SO2 and NOx.The requirements these plants need to comply with will vary: from notifying the competent author-ity when commencing operations of such a plant;

to monitoring and reporting on SO2, NOx and PM emissions. However, what the exact impact on companies concerned will be, will depend on whether the Member State in question already has requirements for medium-sized plants in place and also whether many amendments to these require-ments would be required in order to implement the proposed Directive.In general, it can be concluded that the European Commission is going to push Member States and its industry to take further measures to improve air quality. Therefore, companies should start look-ing into what measures they can take to emit less greenhouse gasses and whether some of these measures are in any way subsidized.

Marlies Huijbers Country Lead The Netherlands

15

Croatia• Radiological and nuclear safety definitions aligned with EU law, requirements for operators stay the same

27-Nov-2013 [52392]• Revised requirements restricting the use of hazardous substances in electrical and electronic equipment

implemented 30-Oct-2013 [50544]

Denmark• Amended Orders in relation to recognised work environment certification 09-Oct-2013 [53395]• Boring restrictions now clearly apply to vertical boring for geothermal heating installations 08-Nov-2013

[53681]• Drinking water protection measures adopted 09-Nov-2013 [53585]• Free allocation of emission allowances under the third EU ETS 01-Nov-2013 [53572]• Statutory Order on explosives 02-Nov-2013 [53541]

European Union• Additional data must be contained by applications for the import or export of halons for critical uses in

aircraft 05-Nov-2013 [53676]• Additional restrictions on the use of certain substances in cosmetic products adopted 25-Nov-2013

[53633]• Approval of etofenprox and aluminium phosphide respectively in insecticides and acaricides and products

used for the control of vertebrates 24-Oct-2013 [53373]• Commission prolongs the validity of the ecological criteria for electrically driven, gas driven and gas

absorption heat pumps 01-Nov-2013 [53098]• Format of the European Technical Assessment (ETA) for construction products adopted 31-Oct-2013

[51770]• Requirements for the protection of drinking water from radioactive substances adopted 07-Nov-2013

[53561]• Revised Commission Decision on the Member State monitoring system classifications as a result of the

intercalibration exercise 08-Oct-2013 [53142]• Six active substances can be included in preservatives 24-Oct-2013 [53359]• Two active substances can be included in preservatives for wood, fibre, leather, rubber and polymerised

materials 04-Oct-2013 [52131]• Use of Silica, Hydrated Silica, Silica Sylilate and Silica Dimethyl silylate in nano form may be revised 02-

Oct-2013 [53335]

Finland• All occupational health services will need written quality management systems 14-Oct-2013 [53338]• Minor amendments to environmental protection requirements for energy producing units 29-Oct-2013

[53347]

France• Content of the application file for an individual decontamination plan for PCB-containing equipment

defined 28-Oct-2013 [52843]• Environmental tax to be paid annually by operators of classified installations handling toxic chemicals 17-

Oct-2013 [53377]• Financial aid for the purchase of clean vehicles reduced 30-Oct-2013 [53111]• Hazardous substance restrictions extended to all types of EEE and conformity assessment procedures

introduced in line with RoHS 2 06-Nov-2013 [48190]• New building with a total floor area between 50 m2 and 1,000 m2 subject to energy supply feasibility

assessment from 1 January 2014 30-Oct-2013 [53594]• Price of electricity from cogeneration installations with a maximum power of 12 MW increased 09-Oct-

2013 [53109]• Second collective scheme for the take-back of professional IT and telecommunications equipment

approved 15-Oct-2013 [53110]• Use of certain types of biocidal products subject to certification from 1 July 2015 09-Oct-2013

[53600]

Continued on page 19

Continued from page 12

Enhesa Flash Feb/Mar 2014 16

Anyone reading this and working for an interna-tional company will likely have a fair few cross-cul-tural stories to tell. I for one hear anecdotes on different cultural approaches and requirements relating to environment and health & safety issues on almost a daily basis.Some of these anecdotes stem from unusual le-gal obligations that we cover for our clients. They can raise a few eye-brows to those of us brought up on EU-led safety-consciousness. For exam-ple, did you know that in India, under the Fac-tories Act 1948 there is a requirement that only adult make workers wearing tight-fitting clothing can examine, lubricate or adjust any machinery in motion? In Russia, under a 2009 Order, did you know if you work in an environment where you may be exposed to ionizing radiation, you are entitled to the regular provisions of free milk? Were you aware that in Pakistan, certain factories are required to provide enough spittoons at con-venient places for their workers?

Of course, although these requirements stand out as being unusual, even humorous, they per-tain to serious subjects: it makes perfect sense that if you are working on machinery with moving parts that loose clothing is extremely hazardous; milk is highly nutritious; and wouldn’t you rather have spittoons than people spitting on the work-floor?Being aware (or unaware!) of local legal obliga-tions are just one of a variety of different types of risk that your company will face doing business, and keeping your people safe and healthy, wher-ever you have locations around the world.As well as variations in law, you will of course also have to contend with differences in culture, lan-guage, professional approaches, customs, holi-days and religious festivals, beliefs and attitudes. All of these factors must be considered when try-ing to manage safety in different locations. (continues on page 17)

Where ismyspittoon?

Tjeerd Hendel-Blackford EHS Regulatory Consultant

Global EHS Risk blog

IOSH 2014 ConferenceEnhesa is delighted to be sponsoring the fore-most health and safety conference in the UK. IOSH 2014, taking place on 17-18 June in Lon-don, offers participants global insights, informa-tive case studies and access to leaders in the field. Attend this year’s IOSH 2014 conference, exploring the core theme of ‘leadership’, to share influence and learn from more than 600 delegates

and over 80 speakers. Plus - for the first time, the conference will be running in conjunction with the Safety & Health Expo, Europe’s largest gath-ering of health and safety professionals. Don’t miss the opportunity to network with over 16,000 exhibitors, visitors and delegates and participate in numerous activities that can contribute to your CPD - all under one roof. For further information, visit www.ioshconference.co.uk.

Enhesa Flash Feb/Mar 2014 17

It is fairly common to hear an EHS manager say “it doesn’t matter what the local law says, we are going to impose our corporate EHS standards on all our facilities all over the world, and because they are based on UK law they will be stricter than anything they have in place at the moment, and the local laws are never enforced anyhow”. There would be little wrong with this approach, if it were true. However, there are many variations in EHS laws around the world that mean this could be a less than sensible approach. Not only that, but do you think it will be easily to tell your site in France or China or Russia or wherever that they will need to apply standards based on UK law? on top of their own legal obligations? Yes, there is a culture of health and safety man-agement in the UK that is more developed (or per-ceived to be more developed) than in some coun-tries, but our research at Enhesa is also finding an exponential rise in the adoption of EHS laws and enforcement of these around the world. Govern-

ments and authorities the world over are moving to protect their workforces more, so the need to be aware of local laws and practices is becoming increasingly important.Have you come across any such issues/anecdotes? It would be good to hear your experiences on this.Enhesa will be sponsoring the conference stream on global risk management at the IOSH confer-ence in London in June 2014.Now where is my spitoon?Tjeerd Hendel-Blackford

IBSI Entropy and EnhesaIn December 2013, Enhesa participated in the BSI Entropy user conference held in Washington DC. Over 50 BSI/Entropy Client companies attended. Gaye van der Eerden’s, Director of Client Relations for Enhesa, presentation on Global EHS Regulatory Trends received high marks for interest and relevance for the group. Enhesa has a strong relationship and history with BSI/Entropy providing EHS regulatory content for over 200 jurisdic-tions to their client companies.

Enhesa Flash Feb/Mar 2014 18

HL

EHS in Buenos AiresWe have a manufacturing location (printing operations) in Buenos Aires, Argentina; there are 500 employees on site. Could you explain to us what our obligations are in terms of Health and Safety staffing and Medical personnel? In Argentina, facilities must provide Occupation-al Medicine and Occupational Health and Safe-ty Services (Servicios de Medicina del Trabajo y de Higiene y Seguridad en el Trabajo), in-house or outsourced at the discretion of the employer.Occupational safety and occupational medicine staffing requirements are both handled by De-cree 1338/96, and are determined by the type/risk of activity and/or the number of “workers equivalent” (trabajadores equivalentes). The term “workers equivalent” is defined as the number of employees who perform production process tasks plus half the number of employ-ees who perform administrative tasks.

With regards to Occupational Medicine Services (Servicio de Medicina del Trabajo), they must be headed by university graduates specialized in Occupational Medicine holding a degree of Occupational Medical Doctor (título de Médico del Trabajo).Facilities employing more than 200 workers in production activities or more than 400 “workers equivalent” must hire, additionally, and for every work shift, a nurse holding a qualifying degree recognized by the relevant authority (título habil-itante reconocido por la autoridad competente).Interested in the full response to this question? Contact helpline@enhesa.com.

Enrique Jaramillo Country lead Argentina

EHS

HelplineInthisregularfeature,EnhesawillprovideextractsofanswerstospecificEHSquestionsthatwehavebeenasked,orthathavebeensentinbyyouthereader.Enhesa’shelplineservicecanhelpanswerEHSquestionsfromanywhereintheworld.

Paul Olagnier Environmental Services Consultant

19

Germany• Additional sanctions for non-compliance with truck loading requirements apply as of 1 May 2014 05-Nov-

2013 [48785]• Companies to determine state of the art for activities involving dangerous substances 21-Nov-2013

[53680]• Exposure to category 1 and 2 CMRs now subject to mandatory occupational prevention, and scope of

register for medical prevention extended 23-Oct-2013 [49394]• Nds: Waste management requirements adapted to Federal Closed Substance Cycle Management Act

31-Oct-2013 [53838]• NRW: Dangerous goods transports competencies 11-Oct-2013 [53370]• NRW: Rules on self-monitoring of sewer systems updated 13-Oct-2013 [53194]• Requirements for phasing out old heating systems and other energy efficiency requirements tightened

18-Nov-2013 [49389]• RP: Waste management requirements adapted to Federal Closed Substance Cycle Management Act 22-

Nov-2013 [53193]• Windparks have no negative impact on the marine environment, according to ecological assessment 31-

Oct-2013 [53195]

Greece• Amended licensing provisions for electricity production from renewable energy sources are issued 01-

Nov-2013 [53844]• Clarifications on the responsible persons to undertake a risk assessment for stevedores working at port

operations are published 07-Nov-2013 [53846]• Guidelines on the payment of insurance contributions of persons who install photovoltaic systems are

published 21-Oct-2013 [53406]• Procedure to apply for a “small scale work permit” in existing buildings 15-Oct-2013 [53389]• Rules on the minimum first aid materials required in the workplace are published 03-Oct-2013 [53387]

Hungary• Energy certificates have to include reference to the Centre for Documentation and Information on Building

20-Nov-2013 [53761]• Extended inspection deadline for older gas fitting equipment and revised regular inspection intervals for all

other equipment apply 19-Nov-2013 [52653]• Fire safety requirements under the National Fire Protection Code are regulated on the level of the Act 21-

Nov-2013 [53758]• Minor editorial amendments to air quality rules adopted to transpose Directive 2010/75/EU on industrial

emissions (IED) 25-Oct-2013 [52207]• More facilities using, producing or emitting hazardous substances will need to comply with stricter

requirements 21-Nov-2013 [53818]

Italy• Tax changes for household and household-like waste: back to the past 28-Oct-2013 [48047]• Vehicle registration guidelines issued for material-handling vehicles (e.g. forklifts and truck-lifts) 15-Oct-

2013 [53451]• WEEE: Italy adopts exemptions to the restrictions on the use heavy metals to comply with EU rules 08-

Nov-2013 [53418]

Lithuania• Additional examples available for the illustrative list of packaging 08-Oct-2013 [51377]• Aircraft operators and operators of installations covered by EU Emissions Trading Scheme can open their

holding accounts in the Union Registry 06-Nov-2013 [53081]• Fire safety rules for ventilation systems adopted 10-Oct-2013 [53078]• Minor change in the IPPC permit application procedure for VOC emitting installations 26-Nov-2013 [53742]

Luxembourg• Additional examples for the illustrative list of packaging published 04-Nov-2013 [52844]• Marine fuels used in Luxembourg need to contain less sulphur from 2014 04-Nov-2013 [51515]

Continued on page 25

Continued from page 15

Enhesa’s Enforcement Tracker service helps you to keep informed about regulatory enforcement struc-tures, trends and policies in 50 selected jurisdictions.Using Enhesa’s proven system of tracking EHS regulatory developments for approaching 25 years, the Enforcement Tracker is a stand-alone, generic, subject specific regulatory monitoring service.Enforcement Tracker gives you a variety of information on how EHS laws are enforced; tracks legislation and proposals that can have an impact on enforcement activities; covers policy announcement and publications regarding government enforcement programs; highlights major cases that have resulted in large fines, shut-downs or even imprisonment for company employees.The Enforcement Tracker is a web-based service, delivered through a single portal site and includes a searchable database. As well as the aforementioned information, the service allows you to: access information on the regulatory structure and law enforcement practices in the countries covered; receive monthly reports regarding enforcement; access to lists of legislation for the countries in question; and participate in quarterly presentations on selected enforcement cases and outstanding issues.Contact us today about accessing Enhesa’s Enforcement Tracker.

AnticipatingLaw Enforcement with the Enhesa Enforcement Tracker™

Japan: RisingdemandforglobalEHS servicesEnhesa is meeting the needs of its clients in Japan

Enhesa Flash Feb/Mar 2014 22

60% of survey respondents said they struggle to obtain the latest regulatory information in foreign countries where they operate.

We at Enhesa have covered Japan as one of our core jurisdictions for over 15 years and have a strong knowledgebase there. To build on our global growth, we started our active marketing efforts on the Japanese market in 2010. As a part of this we have been providing an informative seminar regarding global EHS regulations and

compliance management mainly in Tokyo twice a year. Each event has attracted more than 100 managers and executives from EHS, legal, CSR (Corporate Social Responsibility), and product quality control in major Japanese companies op-erating worldwide, indicating a high interest in the latest regulatory trends in the field.

Most recently, Enhesa held a seminar on global EHS risk management at the Embassy of the Kingdom of Belgium in the heart of Tokyo in November 2013. The seminar was sponsored by the Embassy and jointly provided with the Japa-nese branch of a global certification institute Bu-reau Veritas. Many of more than 100 applicants were EHS professionals at electrical and elec-tronics manufacturers, chemical manufacturers/distributers, oil & energy companies, and service sector. The seminar was opened with honouring opening remarks by Ambassador Luc Liebaut. Ambassador Liebaut welcomed the guests to the Embassy by introducing a friendly relationship be-tween Belgium and Japan in the history. He em-phasized the increasing importance of environ-mental and worker protection for both countries and globally which stimulates the increasing de-mand for specialized organizations that can assist business operators in keeping up with changing regulations and public expectations.

At the start of the seminar, Ms. Yuko Dvor-ak-Miyata, Enhesa’s Business Development and Project Manager, presented the increasing num-ber of environmental, health and safety (EHS) reg-ulations and enforcement cases worldwide. She advised the guests on how to manage EHS risks and integrate EHS management into their core business process. The floor was then passed to Mr. Susumu Yamaguchi, Manager at Omron Cor-poration’s Environment Management Promotion Department. Omron Corporation, headquartered in Kyoto, manufactures and exports industrial au-tomation, high-end electronic components, au-tomotive electronics, social systems and health-care devices around the world. Enhesa has been assisting Omron in developing a global environ-mental compliance audit program and providing its internal auditors with training on regulations and effective compliance audits since 2011. Mr. Yamaguchi shared challenges and solutions in expanding environmental compliance assurance program to overseas facilities. By using Enhesa’s compliance tools and audit and training services, Omron leverages external professionals’ know-how while reinforcing its internal capabilities. Fi-nally Mr. Hisaki Okazaki at Bureau Veritas Japan provided solutions for monitoring and assess-ment of Quality, Health, Safety and Environmental performance through a company group.

We have been providing a seminar on global EHS regulations and compliance in Tokyo twice a year.

Enhesa Flash Feb/Mar 2014 23

A post-seminar survey showed interesting realities of Japanese companies. More than 60% of the survey respondents struggle to obtain the latest regulatory information and understand le-gal requirements accurately in foreign countries where they operate. Only a quarter of the respon-dents engage external professionals to assess EHS compliance status of their overseas facili-ties, although nearly half of the all respondents recognize difficulties in assuring EHS compliance of their local operations or educating local staff regarding compliance. This indicates that Japa-nese companies find themselves in a cloud with-out a clear view where they stand while crossing their fingers that no compliance accidents will oc-cur. This might be a result of the conventional way of doing business – historically Japanese compa-nies would send not only senior executives but also operating managers, all Japanese, hired at their headquarters, to each operation base over-seas and rely on them in day-to-day manage-ment. It was the role of the Japanese managers to assure that operations were carried out in ac-cordance with local regulations.

But in today’s world, not many can afford for expensive expats covering all dimensions of busi-ness risks in each country. At the same time the number of regulations adopted or amended has been increasing and enforcement by the public authorities has been growing in every corner of the world.

As a result, Japanese headquarters do not have the same confidence on governance that they had before as they have less of a clear view of the management of daily operations. EHS compliance risks are therefore now more preva-lent than ever.

Enhesa acknowledges the sharply increas-ing needs of its Japanese clients for assistance in their global compliance management. Our skilled consultants from more than 40 countries alongside our Japanese project managers can help you with your day-to-day EHS compliance management worldwide. For inquiries, contact japan@enhesa.com or +81-(0)50-5534-9789 (in Japanese or English).

Yuko Dvorak-Miyata Enhesa Business Development & Project Manager

Enhesa Flash Feb/Mar 2014 24

Enhesa は日本を重要国の一つとして位置づけ、15年以上にわたって日本のEHS (環境、衛生、労働) 規制について知見を高めてきていますが、さらにグローバル市場での成長戦略として、2010年より日本市場での積極的なビジネスを展開してきました。その一環として、年に二度、主に東京において、グローバルEHS法規制と執行のトレンドに関するセミナーを提供しています。各セミナーでは多国籍に展開する主要日本企業のEHS、法務、CSR (企業の社会的責任)、製品品質管理部門等のマネジャーやエグゼクティブ100名以上から申し込みを受けており、この分野における日本企業の高い関心を示しています。

2013年11月には、在東京ベルギー大使館の後援により、グローバルEHSリスクマネジメント に関するセミナーを主催したところ、電子電気機器、化学、石油・エネルギー、サービス業界のEHS担当者を中心に100名以上から申し込みを受けました。セミナーではリュック・リーバウト駐日ベルギー王国大使より開会の挨拶を賜りました。大使はベルギー王国と日本との歴史的な友好関係について紹介し、セミナー参加者の大使館への来訪を歓迎しました。大使はまた、両国を始めとする世界各国において高まる環境と労働者保護の重要性を強調し、企業が日々変わる法規制と社会からの期待に対応するために専門的な機関への需要が高まっていることが紹介されました。

続いてEnhesa の事業開発及びプロジェクトマネジャー宮田祐子が、世界中で増加する環境と労働安全衛生 (EHS) 関連法令数と厳格化される法執行について紹介し、企業がEHSリスクをどのように管理すればよいか、またEHS管理をビジネスのコアプロセスに組み込む重要性を事例を用いて解説しました。さらに、オムロン株式会社環境マネジメント推進部の山口晋氏より講演を頂きました。オムロン株式会社は京都市に本社を構え、世界中で制御機器、電子部品、車載電装部品、社会システム、健康医療機器などを製造・輸出しています。Enhesaは2011年より、オムロン株式会社におけるグローバル環境遵法監査プログラム開発と、法令理解や効果的な監査手法に関する社内監査員の教育において継続的に支援してきました。山口氏は環境遵法管理プログラムを海外拠点に展開する際の課題とソリューションを参加者に紹介し、Enhesaの遵法ツールと監査及び研修サービスを利用することで、外部専門家のノウハウを活用しながら社内能力を強化してきた過程を共有しました。最後に、世界的な認証機関でありセミナー共催者であるビューローベリタスジャパン株式会社の岡崎久喜氏が、企業グループを通じた品質、衛生、安全、環境パフォーマンスのモニタリングとアセスメントに関するソリューションを提供しました。

セミナー後の参加者アンケートでは日本企業の現実について興味深い傾向が示されました。60％以上の回答者が、事業展開する諸外国において最新の法令情報を取得し法的要求事項を正しく理解することに課題を認識していました。また半数近くの回答者が、現地でのEHS遵法を徹底し現地従業員のコンプライアンス活動について教育することに難しさを感じているにも関らず、海外拠点の遵法状況評価に外部専門家を採用している回答者は4分の1しかいませんでした。これは、多くの日本企業が、例えれば視界の悪い雲の中にいながらコンプライアンス事故が起きないよう手を合せているという現状にあるということを示唆しています。この現状は、海外の各拠点

の経営層だけでなく実務マネジメント層にも本社で採用した日本人マネジャーを駐在させ、日々の管理を担当させるという、従来の海外事業展開手法に因るところがあるのかもしれません。現地オペレーションが各国規制を遵守して遂行されることを担保することは、従来、彼ら日本人マネジャーの役割であったわけです。

しなしながら、今日のビジネス環境にあって、コストの高い駐在員を派遣して各国における全てのビジネスリスクをカバーできる企業は、多くはありません。一方で、新規採択される法令数や法改正の数は増加しており、あらゆる国において法令違反に対する政府の取り締りは厳格化しています。その結果、現地での日々のオペレーション管理の透明性が確保されない中で、日本本社は現地拠点のガバナンスに以前ほどの自信を感じられないでいるのです。

Enhesaは、日本企業におけるグローバル遵法管理支援サービスに対するニーズの高まりを認識しています。40カ国以上から集められた優秀なコンサルタントと日本人のプロジェクトマネジャーが、日本企業の世界中の国々におけるEHS遵法管理を支援しています。お問合せは日本語又は英語にて、japan@enhesa.com 又は050-5534-9789 (日本) までお寄せください。

事業開発 & プロジェクトマネジャー 宮田 祐子

日本市場で高まるグローバルEHS 遵法支援サー ビスへのニーズ

25

Morocco• Companies need to comply with new effluents limits to surface and ground water 28-Oct-2013 [53624]• Companies releasing industrial effluents are now faced with new emission limits 28-Oct-2013 [49861]• Proposal on protected areas 01-Nov-2013 [53641]

Netherlands• Amended requirements for storing liquid fuels in storage tanks adopted 29-Nov-2013 [49731]• Companies under the EU ETS and subject to a risk of carbon leakage can receive a subsidy to compensate

for their market disadvantage 31-Oct-2013 [53040]• Dutch legislation aligned with Biocides Regulation 20-Nov-2013 [53476]• Dutch legislation aligned with Regulation EU/649/2012 concerning the export and import of hazardous

chemicals 31-Oct-2013 [53038]• Inspection requirements for air conditioning equipment in buildings aligned with EU legislation 29-Nov-

2013 [51566]• Minor changes to requirements for EU ETS facilities participating in voluntary Kyoto projects 22-Oct-2013

[53026]• Nature legislation applies to Dutch exclusive economic area as of 2014 25-Oct-2013 [53035]• New fees to be paid under Nuclear Energy Act as of 1 January 2014 05-Dec-2013 [53708]• Parts of ionising radiation legislation to be merged 23-Nov-2013 [53446]

Norway• Amended harmonised classification and labelling for 16 substances under the CLP Regulation 06-Nov-

2013 [50041]• Method to calculate recycling efficiency for waste batteries and accumulators revised 18-Nov-2013 [51132]• Specific requirements for temporary storage of metallic mercury apply 14-Oct-2013 [51146]

Poland• Amended list of areas, habitats and species that are subject to nature protection available 08-Nov-2013

[53658]• Certification requirements for waste managers re-adopted 07-Oct-2013 [49352]• Examples of articles which are considered packaging and which are not considered packaging available

31-Oct-2013 [52310]• Fees and fines for removal and destruction of trees, bushes and green areas in 2014 announced 31-Oct-

2013 [10433]• Fines for exceeding the limits of wastewater discharges and noise in 2014 announced 24-Oct-2013

[31610]• Infrastructure and Development Ministry established 27-Nov-2013 [53697]• Public aid for emissions reduction investments in fuel combustion sources extended 31-Oct-2013 [12077]• Restriction on use of methanol reenacted 03-Oct-2013 [49848]

Portugal• Application form and support documents to apply for an industrial licence revised 16-Nov-2013 [52936]• Building owners and managers to keep records on the buildings system to pump water for fire brigade

use 18-Nov-2013 [53402]• Environmental impact assessment procedure streamlined 31-Oct-2013 [51110]• Generators of radioactive waste and spent nuclear fuel responsible for their sound management 05-Nov-

2013 [51547]• New template of the energy efficiency certificate for retail and administrative buildings 03-Dec-2013

[53499]• Plan of action to control the manufacture and use of pesticides adopted 16-Oct-2013 [52938]• Regulation on hazardous mixtures classification and labelling takes into account Croatia adhesion to the

EU 05-Nov-2013 [53107]• Streamlined rules for managers of industrial sites 16-Oct-2013 [52937]

Qatar• National Committee for occupational health and safety created 28-Oct-2013 [53655]

Continued from page 19

Continued on page 26

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Romania• Certificate of exemption in case of substances used in the interest of defence 29-Oct-2013 [53764]• General conditions for energy generation authorisation and licence to trade, adopted 06-Nov-2013 [53760]• Industrial emissions law adopted 24-Oct-2013 [53759]• Lower bonus values for electricity from CHP and lower reference price for heat energy from CHP in 2014

23-Oct-2013 [53293]• New reference price set for electrical energy in high efficiency co-generation set for 2014 23-Oct-2013

[53291]• State inspection procedure regarding energy performance of buildings and inspection of cooling/heating

systems approved 15-Oct-2013 [53288]

Russia• Adopted criteria for the classification of hydrotechnical installations 02-Nov-2013 [53337]• Adopted Rules for the Technical Inspection of Certain Types of Vehicles 13-Nov-2013 [53712]• Adopted Sanitary Rules for the operation of security x-ray devices 14-Nov-2013 [53714]• Amended provisions on vehicle utilization fee 21-Oct-2013 [53329]• Water protection legislation amended 21-Oct-2013 [53330]

Serbia• Additional substances subject to limitations and bans regarding their manufacturing trade and use 14-Oct-

2013 [52969]• Export and import of dual-use equipment harmonised with the EU framework 31-Oct-2013 [53119]

Slovakia• Adopted Decree requires waste producers to use new templates for their reporting obligations 10-Nov-

2013 [52939]• Facilities storing 2,500 tonnes of heavy fuel have to be classified as major accident hazard installations

09-Nov-2013 [52047]• More stringent requirements apply concerning the use of certain hazardous substances in EEE 09-Nov-

2013 [50661]

Slovenia• Amended Regulation EC/1223/2009 becomes directly applicable in Slovenia, repealing national Cosmetics

legislation 05-Nov-2013 [53085]• Certain installations may be required to monitor the state of surface water quality near their wastewater

outlets 05-Nov-2013 [52375]

South Africa• Changes to the National Air Quality Framework adopted 29-Nov-2013 [16052]• Facilities conducting listed waste management activities must obtain waste management licenses 29-

Nov-2013 [36637]• Facilities intending to construct facilities for treating effluent or wastewater must obtain environmental

authorisations 29-Nov-2013 [46679]• Facilities with dust emissions to undertake dustfall monitoring programmes 01-Nov-2013 [39773]• List of activities requiring atmospheric emission licenses amended 22-Nov-2013 [34402]• National standards aimed at controlling the extraction, flaring or recovery of landfill gas adopted 29-Nov-

2013 [53497]• Operators of small boilers must now meet additional emission restrictions and submit emission reports

01-Nov-2013 [47674]• Vehicle scrapping and recovery facilities must not be constructed in environmentally sensitive areas 29-

Nov-2013 [53496]

Spain• Companies carrying out activities with significant environmental impact are now subject to an streamlined

environmental impact assessment procedure 11-Dec-2013 [50179]• MADRID: Form for the periodical inspections of thermal installations of buildings published 11-Nov-2013

[53511]• Stricter emission restrictions for industrial facilities adopted. 19-Oct-2013 [49976]

Continued on page 29

Continued from page 25

Ergonomics The impact on Health and SafetyVittorio Bollo - NOSA

Enhesa Flash Feb/Mar 2014 28

Ergonomics is one of the most neglect-ed risk factors in many workplaces, and can have tremendous im-pacts on both employee health and productivi-ty. As Valerie Berg Rice states, “Ergonomics is the design of products, places, and processes for safe, effective, and

efficient use by humans.” Ergonomics should form an integral part of any occupational health and safety management system. Yet too often it does not – or, at least, is not included or consid-ered comprehensively enough.

More than comfortSo, why is it that ergonomics is so often ne-

glected by companies? Foremost, it is viewed too simplistically. Many EHS practitioners and man-agement alike tend to view ergonomics as the ‘comfort’ of employees with regard to their tools or equipment or how they work, often with an em-phasis on posture. Posture and issues of muscu-lar-skeletal comfort are indeed very important in ergonomics, but they are not the sum total there-of. Rather, ergonomics must look at the employee and their working environment as holistically as possible. For example, ergonomic considerations should include the psychological impacts on an employee and how they work, as well as the more obvious physical aspects thereof. Monotony in movement at a work station can be as distress-ing psychologically as it can be to an employee’s shoulders or wrists or whatever other part of the body is being impacted by repetitive movements.

To recognize the exacting and multi-disci-plinary facets of ergonomics is to respect it. Af-ter all, ergonomics encompasses a wide array of different and complex disciplines, including bio-mechanics, mechanical engineering, industrial design, anthropometry (the measurements of a given person) and kinesiology (which looks spe-cifically at human movement), as well as physiolo-gy and psychology. Viewed too simplistically, er-

gonomic factors are overlooked or downplayed. And, should that occur, so in time the stresses on the employee’s body can too often result in an array of cumulative trauma disorders (CTDs) with exotic names like carpal tunnel syndrome or De Quervain syndrome and other repetitive strain in-juries (RSIs), not to mention a host of mental dis-orders. The results of these ergonomic disorders can be very debilitating, even life-changing.

A Safety IssueSafety too is affect-

ed by poor ergonom-ics. An uncomfortable or awkwardly postured employee, or one who is disheartened or distract-ed by pain or discomfort, is a hazardous, even potentially dangerous em-ployee, both to themselves and others. Self-med-ication due to pain caused by ergonomic factors can obviously have safety-related consequences, especially where heavy machinery is being used or hazardous conditions prevail. Ergonomics is an excellent example of where there is a health risk, there too is a safety risk.

Ergonomic design that is holistic, comprehen-sive and considers all relevant factors is impera-tive in any meaningful health and safety manage-ment system, so as to ensure more productive, healthier and safer employees in all workplaces.

Vittorio Bollo (R&D) - NOSA

Ergonomics should form an integral part of any occupational

health and safety management

system.

29

Spain (continuation)• Tax on the sale and use of fluorinated greenhouse gases approved 30-Oct-2013 [51259]• Tetrafluoropropene added to the list of authorized refrigerants 14-Oct-2013 [53296]• The illustrative list of packaging in Spain has been extended 03-Oct-2013 [53294]• Voluntary system for the carbon footprint calculation and for the reduction of CO2 emissions subject to

public consultation procedure 23-Nov-2013 [53480]• Waste management requirements for companies generating naturally occurring radioactive materials

adopted 23-Oct-2013 [50180]

Sweden• Free allocation of emission allowances under the third EU ETS 21-Nov-2013 [53717]• List of examples of packaging updated in line with the EU Packaging Directive 15-Oct-2013 [53710]• Revised implementing measures adopted for the EU Ecolabel Regulation in Sweden 26-Nov-2013 [53711]

Switzerland• CO2 tax to increase in 2014 07-Nov-2013 [52294]• GENEVA: Rules on the access to buildings by fire brigades revised for new and renovated buildings 02-

Oct-2013 [53586]• Small photovoltaic panels no longer require planning permit 09-Oct-2013 [49253]

Turkey• Accredited establishments are now required to be involved in Environmental Impact Assessment

procedure 03-Oct-2013 [52951]• Administrative procedure related to registration of greenhouse gas emission reduction projects simplified

09-Oct-2013 [52948]• Companies are not required to have an environmental expert/consultancy if they are exempted from the

environmental licence provision 21-Nov-2013 [48528]• Medical waste transport will be further detailed 05-Nov-2013 [53416]• Minimum working hours of occupational safety experts in certain facilities reduced 11-Oct-2013 [52370]• Scope of health and safety requirements for construction sites extended 05-Oct-2013 [52950]• Strict employment restrictions related to young workers above 16 years of age have been relaxed 25-

Oct-2013 [52982]• Transport of waste oil to be re-regulated 05-Nov-2013 [53415]• Turkey applies ADR 2013 as of 1 January 2014 24-Oct-2013 [52985]• Turkey signed the ILO convention on Promotional Framework for Occupational Safety and Health 08-Oct-

2013 [52949]• Workers’ exposure to dust regulated more strictly 05-Nov-2013 [50910]

Ukraine• Adopted procedure on the record-keeping of emergency situations 09-Oct-2013 [53408]

United Arab Emirates• Abu Dhabi: Companies should expect a code for groundwater extraction 30-Oct-2013 [53306]

United Kingdom• Construction projects to no longer complete Site Waste Management Plans 04-Nov-2013 [51507]• Correction to the glass recycling target and glass remelt calculation formula 14-Nov-2013 [53694]• EU Emissions Trading Scheme carbon price for 2014 29-Nov-2013 [53342]• Further exemptions to the requirement for Certificates of Professional Competence for large road vehicle

driving created 21-Oct-2013 [53411]• Increase in fees for registration of controlled waste carriers, brokers of controlled waste and establishments

undertaking an exempt activity 18-Oct-2013 [52619]• Reclassification of certain types of “household wastes” and further requirements for Waste Transfer Notes

introduced 31-Oct-2013 [53345]• The Building (Amendment No.2) (Wales) Regulations 2013 14-Oct-2013 [53344]• The Pollution Prevention and Control (Designation of Energy Efficiency Directive) (Scotland) Order 2013

12-Nov-2013 [53687]• UK implements derogation to EU rules on placing on the market second hand equipment containing

asbestos 16-Nov-2013 [53672]

Continued on page 31

Continued from page 26

Need to stay on top of compliance in a new jurisdiction? Enhesa is constantly expanding its geographical coverage, and can currently cover over 200 national and regional jurisdictions worldwide. We often get requests from clients to develop services for a new jurisdiction. Through our extensive client base we are often able to also find others interested and this enables us to offer competitive prices for these.Please contact us to find out more at protocols@enhesa.com or call us at 1.202.552.1090 (US) or +32-(0)2.775.9797 (EUR) for further details.

New protocols?What about sharing development costs?

More than 200 up-to-date Audit Protocols readily available worldwide

31

Asia-PacificAustralia

• NICNAS invites comments on existing chemical assessments 22-Nov-2013 [48085]• NSW: Changes made to the way that mining project proposals are assessed 04-Nov-2013 [51621]• NSW: Legislation for mining and petroleum rights clarified for public interest and development consents

13-Nov-2013 [53786]• NSW: Work Health and Safety Act amendments passed to strengthen prosecution powers 26-Nov-2013

[53158]• NT: Offence created for non-compliance with directions from emergency officers 27-Nov-2013 [53556]• Production of coal char and glass wool are emissions-intensive trade-exposed industry under the Jobs

and Competitiveness Program 25-Nov-2013 [53660]• Public comment sought on draft stevedoring Code of Practice 29-Oct-2013 [52997]• Queensland: New requirements for carrying out electrical work on energised equipment and operating

plant near electric lines 19-Nov-2013 [49710]• SA: Amendment passed to provide incentives for landowners to manage native vegetation clearance

sustainably 05-Dec-2013 [53626]• SA: Young employee drivers will be required to carry an exemption letter from employers for night driving

or for carrying more than one passenger 14-Nov-2013 [53629]

China• Approved Standards containing technical criteria impacting EHS - November 2013 30-Nov-2013 [53608]• BEIJING: Government to take emergency response measures to address air pollution problems 21-Oct-

2013 [52980]• BEIJING: Measures for carbon emission quota trading provided 22-Nov-2013 [53439]• BEIJING: Stricter dust pollution control requirements at construction sites imposed 25-Oct-2013 [53189]• CHENGDU: Certain facilities emitting air pollutants need to complete an air pollutant data investigation

21-Nov-2013 [53462]• CHENGDU: Facilities generating construction waste will have to comply with stricter requirements for the

waste disposal from 1 January 2014 08-Oct-2013 [53002]• Cosmetic manufacturers are no longer required to obtain an Industrial Product Production License 11-

Oct-2013 [52185]• Detailed requirements imposed in relation to the construction, use, and maintenance of urban wastewater

discharge systems 02-Oct-2013 [52567]• Emergency response plan drafting guidelines updated 19-Oct-2013 [53529]• Explanatory notes issued in relation to terminologies and timelines prescribed in the Regulation on Safety

Accident Reporting and Investigation 20-Nov-2013 [53527]• Full Environmental Impact Assessment reports/statements will be released for the public scrutiny under a

new Regulation 14-Nov-2013 [53471]• HEBEI: Detailed measures to control dust pollution at construction sites provided 10-Oct-2013 [52562]• HEBEI: Strengthened qualification and safety training requirements imposed on industrial facilities 28-Oct-

2013 [53528]• HENAN: Facilities emitting heavy air pollution have needed to conduct a self-inspection since 15 October

2013 15-Oct-2013 [52564]• HENAN: Use of pollution prevention and reduction technologies to be promoted 14-Nov-2013 [53531]• JIANGSU: Hazardous Chemical Companies are required to continue to conduct incident risk assessments

in compliance with the existing regulations 22-Nov-2013 [52628]• JIANGSU: Stricter fire prevention requirements imposed on high risk facilities 25-Oct-2013 [53011]• Periodical random inspections will be carried out to strengthen the enforcement of safe production

requirements 30-Oct-2013 [52561]• QINGDAO: Safety inspections to be conducted on chemical and pharmaceutical companies using

hazardous chemicals 14-Nov-2013 [53534]• Safety hazard identification checklist issued for industrial facilities and commercial trading companies in

designated industries 04-Nov-2013 [53472]• SHANDONG: Financial incentives provided for the early scrappage of vehicles that fail to meet certain

emission standards 25-Oct-2013 [53540]• SHANGHAI: Detailed regulations issued in relation to carbon emission trading 18-Nov-2013 [53547]• SHENZHEN: Industrial wastewater needs to comply with different standards on the basis of wastewater

categories 23-Oct-2013 [53232]

Continued from page 29

Continued on page 33

Enhesa Flash Feb/Mar 2014 32

HL

Cosmetics in ChinaWe are a chemical company considering manufacturing Dipropylene Glycol (DPG) and Tripropylene Glycol (TPG) in Singapore. We would export all the manufactured DPG and TPG from Singapore to China and sell them to manufactures in China as a cosmetic ingredient. What would our regulatory obligations in China be as a cosmetics raw material supplier in terms of permitting/registration? The question is quite a broad one, but we put our in-house China team onto the issue! Here is their response:With regards to the permitting side of your question, no specific importing permits need to be obtained when importing DPG or TPG2 into China. However facilities using new cosmetic raw materials to manufacture cosmetic prod-ucts (“Cosmetic product manufacturers”) must obtain an approval from the State Food and Drug Administration.

The applicant for this approval can be either the raw material manufacturer or the cosmetic product manufacturer. At present it is not sure whether DPG and TPG should be regarded as new or existing cosmetic raw materials in Chi-na, and consequently Enhesa cannot state for sure whether these substances need approval. According to the State Food and Drug Admin-istration, if a facility can prove that certain cos-metic raw materials (like DPG and TPG) have already been used for manufacturing cosmetic products in China, no approval is required.Interested in the full response to this question? Contact helpline@enhesa.com

Ellen Zhang EHS Regulatory Consultant

Product

HelplineInthisregularfeature,EnhesawillprovideextractsofanswerstospecificProductquestionsthatwehavebeenasked,orthathavebeensentinbyyouthereader.Enhesa’sproducthelplineservicecanhelpanswerspecificproductquestionsfromanywhereintheworld.

Paul Olagnier Environmental Services Consultant

33

China (continuation)• SHENZHEN: Stricter dust pollution control measures at construction sites provided 06-Nov-2013 [53517]• Streamlined application procedures imposed for reviewing the environmental impact assessment report of

oceanic construction projects 08-Oct-2013 [53274]• Stricter air pollution control measures expected in the winter season 01-Nov-2013 [53605]• TIANJIN: Facilities that use boilers or generate dust are subject to an inspection on pollution reduction

11-Nov-2013 [53538]• TIANJIN: Facilities using coal-fired boilers need to conduct a self-inspection from 20 October 2013 to 27

October 2013 14-Oct-2013 [53012]• Total of 28 chemical classification and labeling standards issued to implement GHS Fourth Revision in

China 10-Oct-2013 [50103]• ZHEJIANG: Procedures for the application of the pollutant discharge fee reduction, waiver, or postponement

provided 14-Oct-2013 [53006]• ZHEJIANG: Registration procedures for companies that import hazardous chemicals clarified 08-Nov-

2013 [53277]• ZHEJIANG: Stricter VOC pollution control requirements provided 04-Nov-2013 [53145]

Hong Kong• Detailed rules issued for determining the applicable emission standards for designated vehicles 25-Oct-

2013 [53062]• Government strives to increase the waste disposal capacity in Hong Kong 29-Nov-2013 [53575]• List of Technical Instructions for the Safe Transport of Dangerous Goods referred to in Hong Kong civil

aviation legislation updated 15-Dec-2013 [53063]• Stricter restrictions imposed on the sales, supply, and storage of glycopyrronium and its salts 16-Oct-2013

[52049]• Stricter restrictions imposed on the sales, supply, and storage of mirabegron and pasireotide and their

salts 27-Nov-2013 [53574]

Japan• Details on requirements imposing earthquake resistance evaluation and reporting on certain office and

hazmat buildings prior to 1981 determined 09-Oct-2013 [50573]• Manufacturers and importers of AC electric motors and LED bulbs will be subject to energy efficiency and

labeling requirements 25-Oct-2013 [53105]• New earthquake-resistance standards for escalators and elevators determined 29-Oct-2013 [53104]• Specific spherical tanks must satisfy new safety standards on braces as of 1 January 2014 29-Nov-2013

[53571]• Standards to withhold registration of agricultural chemicals updated 21-Oct-2013 [53106]• Standards to withhold registration of agricultural chemicals updated 29-Nov-2013 [53569]• Users of specific forestry machines will be subject to tighter safety controls as of 1 June 2014 29-Nov-

2013 [53570]

Malaysia• Companies supplying hazardous chemicals are now subject to GHS requirements for classification and

labelling 11-Oct-2013 [9228]• Mining companies conducting blasting activities must submit a blast management plan 21-Nov-2013

[53813]

New Zealand• Amendment to the Maritime Transport Act strengthens maritime safety and shipping pollution liabilities

22-Oct-2013 [53103]• Amendments made to the Building Act to clarify obligations and improve accountability 27-Nov-2013

[41574]• Changes adopted to the site and storage conditions for aerosols relating to building and room separation

distances 07-Oct-2013 [51235]• Legislation adopted to strengthen management of offshore activities potentially causing environmental

effects. 22-Oct-2013 [46509]• Legislative changes made to enhance health and safety in the mining sector 18-Nov-2013 [51010]• New dedicated workplace health and safety agency “WorkSafe New Zealand” in place as of 16 December

2013 18-Nov-2013 [49121]

Continued from page 31

Continued on page 35

0 5 10 15 20 25

Enhesa Flash Feb/Mar 2014 34

Stay tuned for Enhesa’s Flash Special Edition high-lighting EHS management systems and platform solutions. In just a matter of weeks, we’ll publish a resource packed Flash to detail how Enhesa has made its EHS and product regulatory content plat-form-ready, provide useful information on our plat-form partners, and divulge the results of our survey published a few months to gather information on your management system needs. We’re at the forefront of ensuring that the best solutions are available for EHS management.The upcoming Special Edition Flash will mark the grand reveal of “Enhesa XML” Compliance with en-vironmental, health & safety (EHS) regulations or product regulations are amongst the key concerns of many corporate managers. It is an increasingly com-plex challenge as regulations become more and more complex and differ a lot from one country to the other. Enhesa has developed a number of tools and ser-vices to facilitate getting access to the relevant reg-ulations, understanding what they require from you and providing analysis and guidance on how to meet these requirements.An increasing number of companies are implement-ing Enterprise Resources Platforms or Information Management Systems, which has prompted Enhesa to adjust its offering accordingly. The Enhesa compli-

ance services and tools can be obtained through an XML datafeed. It assumes that you have either select-ed a commercially available platform or that you have built your own system that is capable of receiving some of the datafeed. In that regard, “EnhesaXML” is, as its name implies, about using XML to deliver data to clients.Enhesa currently maintains a series of partnerships with a variety of commercially available platforms. The Special Edition will detail these partnerships and ex-plain how we work with each to integrate our global regulatory content with the unique functionalities of the platform solutions.In addition, we will publish detailed results of our sur-vey that Enhesa designed to understand your needs when it comes to a management system. The sur-vey was previously published in 2013, but will remain open until final publication so that we gather the most intuitive results. As a sneak peak, we have compiled the current results for the primary objectives consid-ered when selecting a platform. While factors like improving sustainable performance are quickly be-coming a factor when selecting an EHS management system, the main reason still remains streamlining and standardizing EHS or product compliance assurance. You can contribute results to our survey. For more information please contact marketing@enhesa.com

StayTunedSneak peak at Enhesa’s upcoming Special Edition Flash

Streamline and standardize EHS or product compliance assurance

Better reporting across facilities and at corporate level on EHS or p...

Reduce occupational accidents and illnesses

Reduce environmental impact

Improve sustainability performance

other

When selecting a platform, what are your primary objectives?

Special

35

Singapore• Additional Codes of Practice approved to be used in conjunction with Workplace Safety and Health

legislations 04-Dec-2013 [53822]• Companies undertaking any building works including demolition and erection are subject to more stringent

regulations 25-Oct-2013 [53022]

South Korea• Two additional chemicals designated as toxic chemicals under the Toxic Chemicals Control Act 10-Oct-

2013 [52199]

Thailand• Companies engaging in groundwater activities are subject to stricter requirements 11-Oct-2013 [53092]• Companies manufacturing, importing, exporting or possessing Type 2 hazardous substances can notify

or register online 26-Nov-2013 [53552]• Companies working with hazardous substances are required to comply with notification and safe handling

requirements 29-Nov-2013 [53553]• Factories manufacturing or using 1,2-eichloroethane or vinylchloride are subject to new procedures for

measuring air emissions 22-Nov-2013 [53554]

Vietnam• Administrative sanctions and the amounts of fines against the violations of the economically efficient use

of energy regulations published 17-Oct-2013 [53361]• Administrative sanctions and the amounts of fines against violations of chemical safety, fire-fighting and

environmental regulations published 12-Nov-2013 [53701]• Amendment of the regime of allowances in kind to employees exposed to dangerous and hazardous

working conditions to become effective 5 December 2013 18-Oct-2013 [53364]• List of work-related diseases provided basic for duration that employees can take a long-term sick leave

for necessary treatment published 28-Oct-2013 [53698]• Lists of priority targets, priority sectors, and urgency criteria in social-economic development planning in

response to climate change published 17-Oct-2013 [53362]• Region-based minimum wages will apply as of 1 January 2014 14-Nov-2013 [53699]• Strictly administrative sanctions and higher fine rates imposed on violations against water resources

regulations published 24-Oct-2013 [53365]• Vietnam National Chemical Group is given expanded roles regarding chemical manufacturing and trading

in Vietnam as of 5 January 2014 21-Nov-2013 [53700]

AmericasArgentina

• Air conditioners to comply with stricter minimum energy efficiency standards 06-Nov-2013 [53440]• Extended suspension of increase in environmental insurance coverage for companies transporting

hazardous substances and waste 09-Oct-2013 [50991]• Mandatory minimum energy efficiency standards applicable to electric equipment 07-Oct-2013 [53355]

Brazil• Contingency plan for oil and gas installations adopted 23-Oct-2013 [53010]• Copper sulfate and hydrogen peroxide based pesticides for emergency use by the SABESP can benefit

from simplified registration 01-Nov-2013 [53269]• GOIÁS: Amendments to the State Fire Safety Code 13-Feb-2014 [53804]• Less strict rules for the renewal of license registrations for the extraction and exploration of sands, gravels,

clay and related mineral substances 03-Oct-2013 [53275]• MINAS GERAIS: Companies supporting sport activities can use label to promote their services and

products 30-Nov-2013 [53805]• MINAS GERAIS: New grace period for late payment of the mining fee corresponding to April-September

2012 25-Oct-2013 [53258]• PPE certification requirements amended 18-Nov-2013 [53803]• Registration waiver for the import of pesticides containing emamectic benzoate 07-Nov-2013 [53792]• RIO DE JANEIRO: Facilities subject to environmental licensing must pay environmental compensation 01-

Nov-2013 [53255]

Continued on page 38

Continued from page 33

Enhesa Flash Feb/Mar 2014 36

As auditors, we often repeat the mantra ‘if it isn’t documented, it didn’t happen’. A significant part of any audit process is document review.Auditors want to see documented evidence of what the site has done to comply with its legal EHS ob-ligations. Reviewing documents can be time con-suming so one of the biggest things an auditor can do to ensure a smooth audit process is to prepare the site to be able to provide access to those docu-ments in advance.Anyone preparing for an audit needs to answer a couple of key questions:

Where are our documents stored?It is important to identify where certain documentation is kept. Some companies have one computer based document management system such as Share Point while others may have separate systems for tracking equipment maintenance. In some cases certain doc-uments may be stored in paper form and kept at a number of locations across the site.

How will we give auditors access?Any documents that are able to be collected togeth-er should be placed in a room for the audit team. Access needs to be arranged for documents which are stored in an online system. There may be a need to print off some of the most crucial documents but a lot of them will be able to be provided electronical-ly or reviewed onscreen if appropriate access points have been arranged.If the information is stored across the site you may want to identify key document holders and arrange the audit schedule to make sure the auditors meet with these key people at the location where the doc-uments are stored. If some documents are highly sensitive you may need to ensure the auditors have the correct clearance to view these.

Checking that the most recent version of a document has been made available is also important. Auditors can only judge compliance on what they see at the time. Providing the incorrect version of documents could lead to confusion regarding whether the site is or isn’t meeting its legal obligations.Some large or complex documents such as permits may need to be made available to the auditors in advance so they can use their time during the audit effectively. Enhesa’s auditors find that the burden of gathering and organizing the mountains of paper to be re-viewed during an audit is greatly simplified the use of the “Related Documents” functionality of the En-hesa ScoreCard. For each regulatory requirement contained in the Audit Protocol, the Enhesa Score-Card identifies any particular documentation that should be relied upon to assess compliance. A list of these related documents is compiled in a discreet section of the ScoreCard where the documents are classified as either, to prepare for review during the audit or to send to the auditor in advance. By providing this list of documents to the site well in advance of showing up at a site, Enhesa’s audi-tors have an easy way to alert the facility to precisely what it is they will want to see. This allows the facility ample time to organize the information as well as raise any questions they may have. By minimizing the time spent on-site searching for paperwork, En-hesa auditors are better able to focus their attention providing higher value services to our clients.

This is just one of the many ways that Enhesa ensures its audit programmes are easy to implement and that you get the most value for money. Contact Enhesa today to find out how we can help you ensure your EHS programme is performing at its very best.

Laura Smith Enhesa Project Manager, Auditing Services

Ifitisn’tdocumented, itdidn’thappenDocument preparation – the key to a successful audit

Audit Tip

1 Identify and understand applicable requirements 2 Assess Compliance

3 Stay up to date as requirements change

Do you have difficulties keeping track of the never-ending stream of new EHS regulatory requirements? Do you want to be able to identify what directly applies to your various facilities in different countries? Do you want to be able to verify and ensure you have done what needs to be done? Do you want to be able to demonstrate and document compliance at both corporate and facility level?The Enhesa Compliance Manager is a three step easy-to-use, web-based solution that combines the best elements of Enhesa’s various regulatory compliance assurance services.For a demo of the Enhesa Compliance Manager, please contact us by email at enhesa@enhesa.com

Your Global EHS Regulatory Compliance in 3 steps

Enhesa ComplianceManager

38

Brazil (continuation)• RIO DE JANEIRO: New requirements and procedures for environmental authorization to drill water wells

08-Oct-2013 [53273]• SÃO PAULO: Activities involving native Brazilian flora species in the Mata Atlântica biome are subject to

specific procedures and requirements 24-Oct-2013 [53254]• SÃO PAULO: Analysis of physical, chemical and biological tests on environmental matters to be done by

accredited laboratories only 22-Oct-2013 [53252]• SÃO PAULO: Specific environmental licensing rules for nautical support structures and installations adopted

25-Oct-2013 [53253]• Temporary reduction of import tariffs for pesticides 26-Nov-2013 [53819]

Canada• ALBERTA: New Alberta Environmental Monitoring, Evaluation and Reporting Agency to be established in

early 2014 11-Dec-2013 [51492]• BRITISH COLUMBIA: Oil and gas facilities to comply with new regulation detailing emergency response

program and plan requirements starting Oct 2014 08-Oct-2013 [51493]• Minister of Transport announces Protective Direction to require transporters of crude oil to conduct

classification tests 17-Oct-2013 [48383]• Ministry of Environment adopts revisions for eligible projects that require environmental assessments 06-

Nov-2013 [53410]• Ministry of Environment exempts heating distillate oil from the 2% renewable content requirement 06-Nov-

2013 [47868]• Ministry of Environment removes notification and assessment requirements for formaldehyde polymers and

other substances 20-Nov-2013 [48917]• ONTARIO: Ministry of Environment clarifies requirements for renewable energy approvals 21-Oct-2013

[50781]• ONTARIO: Ministry of Labour finalizes minimum occupational safety and health training requirements for

employees 15-Nov-2013 [51487]• QUEBEC: Minor changes established in the functioning of the Quebec cap-and-trade system 13-Nov-

2013 [53648]• Risk management instruments will be developed for Perfluorooctanoic acid that was added to the Toxic

Substances List 06-Nov-2013 [47470]

Chile• New occupational health and safety authority established 14-Oct-2013 [53407]• Regulation on the construction of containers used for transporting hazardous chemical products amended

07-Oct-2013 [53403]

Colombia• Colombia adopted the Minamata Convention on mercury 11-Oct-2013 [52931]• Colombia published the procedure for exploring and exploiting non conventional hydrocarbons fields 08-

Oct-2013 [52930]

Costa Rica• Domestic market for stored, reduced and avoided carbon emission created 11-Nov-2013 [53438]• Regulation on the internal functioning of the National Commission of Risk Prevention and Emergency

Response adopted 15-Nov-2013 [53433]• Suspension to the amendments to the procedure to obtain environmental licenses adopted 20-Nov-2013

[53533]

Ecuador• Minimum safe manning conditions for ships operating in Ecuadorian waters 07-Oct-2013 [53300]• Voluntary Standard on environmental management of products adopted 04-Oct-2013 [53234]• Voluntary standard on the construction of solar panels adopted 04-Oct-2013 [53235]• Voluntary Standard tests and manufacture of electricity metering equipment adopted 04-Oct-2013 [53237]

Mexico• Additional safety requirements to be implemented for household heaters 14-Oct-2013 [52954]• Mexican standard on admission of hazardous goods in ports updated 21-Oct-2013 [53126]

Continued from page 35

Continued on page 39

39

Mexico (continuation)• Oil industry waste to be included in special management waste standard 12-Nov-2013 [53429]• Permit holders for LPG activities to submit compliance verification technical report in 2014 29-Nov-2013

[53739]• Specifications for manufacturing of LP gas or natural gas connectors and regulators updated 16-Oct-

2013 [53125]• Technical standards on water sampling and vehicles with internal combustion engines approved 13-Nov-

2013 [53430]• Updated list of fossil fuels to identify users with high energy consumption patterns published 29-Nov-2013

[53740]

Peru• Application format for submittal of Risk Study and Contingency Plan approved 16-Oct-2013 [53162]• Companies are now able to voluntarily correct environmental legislation minor importance breaches 27-

Nov-2013 [53768]• Companies must use registered and authorized environmental companies to develop environmental

impact studies 15-Nov-2013 [53428]• Criteria for the performance of environmental impact studies of projects and activities that potentially can

harm water resources clarified 29-Nov-2013 [53767]• Energy production to be increased through bidding proposals 17-Oct-2013 [53164]• Environmental liability sites list to be updated 11-Oct-2013 [52963]• Internal Regulation for the National Court for the Resolution of Water Controversies approved 26-Oct-

2013 [53167]• Manufacturers of electric and electronic equipment and liquid fertilizers to comply with updated Peruvian

Technical Standards 18-Oct-2013 [53165]• New projects in the Agrarian Sector to follow amended procedures in the environmental approval process

29-Oct-2013 [53169]• Peruvian Technical Standard on environmental management approved 06-Oct-2013 [52959]• Pesticide manufacturers to comply with updated Peruvian Technical Standards 06-Oct-2013 [52960]• Procedure that owners of private conservation areas must follow to be recognized as National Natural

Protected Areas published 14-Nov-2013 [53427]• Requirements for employers to protect workers from exposure to solar radiation adopted 06-Nov-2013

[53424]• The Information System for electronic submittal of Citizen Participation Plans and Terms of Reference for

Hydrocarbon and Power Generation is approved 11-Oct-2013 [52962]• Violations and sanctions established for administrative environmental non-compliance 16-Oct-2013

[53163]• Violations and sanctions for exceeding maximum permissible limits established 13-Nov-2013 [53425]

United States• ATSDR releases interaction profile for Chlorinated Dibenzo-p-Dioxins, Polybrominated Diphenyl Ethers,

and Phthalates 25-Oct-2013 [53094]• CALIFORNIA: Governor signs bills to address state water shortage 08-Oct-2013 [52863]• CALIFORNIA: Legislature passes law requiring additional compensation to employees for rest or recovery

period not provided 10-Oct-2013 [53238]• CALIFORNIA: OEHHA adopts Reference Exposure Level for caprolactam 18-Oct-2013 [34964]• DELAWARE: Amendments to Delaware’s CO2 budget trading program 01-Dec-2013 [49722]• DELAWARE: Amendments to infectious waste labeling and packaging regulations 01-Nov-2013 [51229]• DELAWARE: Delaware removed from multi-state Nitrogen Oxides Budget Trading Program 01-Nov-2013

[51227]• Department of Energy finalizes efficiency test procedures for showerheads, faucets and other plumbing

equipment 23-Oct-2013 [45254]• DOE finalizes energy conservation test procedures for televisions 25-Oct-2013 [43460]• EPA adopts amendments to Greenhouse Gas Reporting Rule regarding calculation and monitoring

methodologies for electronics manufacturing 19-Nov-2013 [47089]• EPA withdraws three direct final SNURs 05-Nov-2013 [52191]• Facilities that manufacture, process or use ortho-nitrotoluene are required to report release information

under EPA rule 07-Nov-2013 [49836]• FLORIDA: DEP implements a comprehensive permitting program for activities impounding or obstructing

surface water and repeals previous rules 14-Nov-2013 [50366]

Continued from page 38

Continued on page 40

40

USA (continuation)• GEORGIA: EPA redesignates Atlanta area to attainment for ozone 02-Dec-2013 [49076]• ILLINOIS: Amendments to RCRA permit program 08-Nov-2013 [51676]• ILLINOIS: Incorporation by reference of and minor state amendments to hazardous waste management

regulations 08-Nov-2013 [51681]• ILLINOIS: Incorporation by reference of certain 2012 federal transportation regulations 15-Nov-2013

[52206]• ILLINOIS: Minor amendments to process for obtaining an EPA identification number under used oil

regulations 08-Nov-2013 [51683]• INDIANA: Adopted amendments to air standards in construction permits 02-Oct-2013 [50841]• INDIANA: IDEM adopts emergency rulemaking for federal nonattainment designations for sulfur dioxide, 8

hour ozone and PM 2.5 23-Oct-2013 [53053]• INDIANA: IDEM adopts lower thresholds for facilities that can qualify for minor new source review

requirements 23-Oct-2013 [43031]• IOWA: DNR amends Iowa clean air regulations relating to nonattainment areas 11-Dec-2013 [52517]• IOWA: Elevator Safety Board adopts increased fees for elevator permits and inspections 30-Oct-2013

[52515]• IOWA: Elevator Safety Board adopts relevant portions of most recent ASME standard for platform lifts and

stairway chairlifts 11-Dec-2013 [53837]• IOWA: Environmental Protection Commission issues revised leak detection methods for underground

storage tanks operated at unstaffed facilities 16-Oct-2013 [48429]• IOWA: Labor Services Division broadens the exemption for facilities that operate digger derricks under the

federal construction safety standard 02-Oct-2013 [53136]• KENTUCKY: DEP adopts brownfields development program 01-Dec-2013 [52767]• LOUISIANA: Revised coastal mitigation rules adopted 20-Oct-2013 [51925]• MAINE: Amendments to the CO2 budget trading program finalized 27-Nov-2013 [52412]• MARYLAND: MDE reissues general industrial stormwater permit 01-Nov-2013 [50235]• MASSACHUSETTS: Department of Public Safety amends hoisting machinery regulations 08-Nov-2013

[47176]• MASSACHUSETTS: MassDEP adopts final regulations increasing permit/compliance fees and amending

permit application timely action schedules 22-Nov-2013 [51667]• MICHIGAN: DEQ finalizes amendments intended to streamline hazardous waste management requirements

15-Nov-2013 [50281]• MICHIGAN: DLLR adopts amendments to incorporate updated boiler safety standards 15-Nov-2013

[51266]• MICHIGAN: DLRA adopts amendments to incorporate updated federal standards for process safety

management of highly hazardous chemicals 15-Oct-2013 [51287]• MICHIGAN: DLRA adopts amendments to occupational health standards for carcinogens 15-Oct-2013

[50827]• MICHIGAN: DLRA adopts amendments to occupational health standards for vinyl chloride 15-Oct-2013

[50831]• MICHIGAN: Governor signs law that eliminates sodium effluent limit restrictions for ground water discharges

26-Nov-2013 [53667]• MICHIGAN: MDEQ amendments provide more time to begin construction under air pollution Permit to

Install procedures 15-Nov-2013 [50826]• MICHIGAN: MIOSHA proposes updates to state hazardous waste and emergency response safety

standards as part of state’s standards improvement project 15-Nov-2013 [53662]• MICHIGAN: MIOSHA releases 2013 Field Operations Manual to describes agency enforcement procedures

22-Nov-2013 [53669]• MISSOURI: Department of Natural Resources finalizes a number of significant air regulations that apply to

major sources 03-Oct-2013 [52646]• MISSOURI: Department of Natural Resources proposes changes to the state emergency plan for dealing

with emergency episodes of high air pollution 01-Nov-2013 [51633]• MONTANA: DEQ adopts most recent Standards for Subsurface Water Treatment Systems 14-Nov-2013

[48077]• MONTANA: DEQ finalizes new requirements for the transportation of infectious waste to treatment facilities

prior to final disposal 17-Oct-2013 [52055]• MONTANA: DEQ finalizes removal of requirement to provide corrosion protection for pipes that may contain

regulated substances 17-Oct-2013 [52057]

Continued from page 39

Continued on page 41

41

USA (continuation)• MONTANA: DNRC withdraws revisions to water use regulations that would modify the definition of a

combined appropriation of water 14-Nov-2013 [52059]• NEBRASKA: Department of Labor increases the inspection fees for escalators, moving walks, conveyors,

and dumbwaiters 26-Nov-2013 [53052]• NEW HAMPSHIRE: DES adopts carbon dioxide budget trading program, offset projects, and allowance

auction programs 05-Nov-2013 [52875]• NEW HAMPSHIRE: NHDES adopts public water system operational and maintenance requirements 24-

Oct-2013 [52876]• NORTH CAROLINA: Adopted amendments align state radiation protection regulations with federal

requirements 01-Nov-2013 [50800]• OHIO: DOH adopts revisions to radiation regulations regarding financial assurance for decommissioning

and transfer of licenses 12-Nov-2013 [52773]• OHIO: DOH revises radiation control regulations to require licensees to conduct surveys of subsurface

radioactivity 04-Nov-2013 [52061]• OKLAHOMA: Emergency amendments to general requirements and emission inventory reporting for

permit-by-rule minor sources 15-Oct-2013 [50804]• OREGON: DCBS finalizes revisions to occupational safety and health rules for using cranes and derricks

in underground construction 09-Oct-2013 [52193]• OREGON: DEQ adopts a fee increase of 20% for Air Contaminant Discharge Permits 01-Dec-2013 [53560]• OREGON: DEQ adopts fee increases for water permits 01-Dec-2013 [51765]• OREGON: DEQ adopts revised NAAQS for lead, SO2 and NO2 for consistency with federal requirements

01-Dec-2013 [51766]• OSHA amends standard for mechanical power presses 20-Nov-2013 [53623]• OSHA updates general industry and construction signage standards to reflect current national consensus

standards 06-Nov-2013 [51298]• PHSMA amends requirements for inspection of perishable hazardous materials 02-Oct-2013 [50932]• RHODE ISLAND: Amendments align state CO2 Budget Trading Program with 2012 changes to RGGI

Model Rule 01-Dec-2013 [53089]• SOUTH CAROLINA: DHEC adds 4 sources to the list of air pollution sources that are exempt from obtaining

a construction permit 22-Nov-2013 [53704]• TEXAS: TCEQ amends surface coating requirements 14-Nov-2013 [50737]• TEXAS: Voters pass state water initiative 05-Nov-2013 [50742]• TEXAS: TCEQ adopted rulemaking to set out maximum and minimum disposal rates that TCEQ may

charge generators of low level radioactive waste 22-Nov-2013 [51212]• UTAH: DEQ adopts rule outlining emissions limits for VOCs from the use of architectural coatings 15-Nov-

2013 [51728]• UTAH: DEQ revises requirements for the approval of new or modified sources of air emissions 01-Nov-

2013 [52070]• UTAH: DEQ revises rule for setting comment periods for groundwater discharge permits 15-Nov-2013

[52781]• UTAH: DOT incorporates by reference recent changes to federal hazardous materials transportation

requirements 15-Oct-2013 [52202]• VIRGINIA: Adopted amendments exclude trans-1,3,3,3-tetrafluoropropene from the definition of “volatile

organic compound” 21-Oct-2013 [52579]• VIRGINIA: Amendments enhance groundwater protection and expand the Eastern Virginia Groundwater

Management Area 04-Nov-2013 [47305]• VIRGINIA: Amendments to 2014-2018 General Permit for Discharges of Pesticides to Surface Waters 21-

Oct-2013 [50226]• WASHINGTON STATE: Adopted amendments aligning state ambient air quality standards with federal

standards 21-Nov-2013 [49612]• WASHINGTON STATE: Adopted amendments expand the work that specialty electricians can perform

04-Nov-2013 [50790]• WASHINGTON STATE: Adopted amendments to safety regulations for elevators 27-Nov-2013 [47766]• WASHINGTON STATE: Increase for certain wastewater and stormwater permit fees 01-Nov-2013 [50788]

Uruguay• Extension of parental leave enacted 13-Nov-2013 [53441]• Facilities transporting cargo by road have to register with transport authorities 12-Nov-2013 [53576]• Law on subsidies to encourage youth labor adopted 12-Oct-2013 [52992]

Continued from page 40

Enhesa Flash Feb/Mar 2014 42

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WebinarsMarch 18 & 20 Enhesa Webinar: The challenges of auditing EHS all around the worldInthiswebinar,DawnKrawczakandJackWelschwillbesharing theirvastEHScomplianceauditingexperiencewithyou.Dawnhasmanagedcorporateauditprogramsandconductedaudits in locationsallaroundtheworldusingEnhesa’sAudittools.Dawnhasawealthofknowl-edge and understanding of the linguistic, cultural andregulatorychallengesauditorsface.Jack has lead Enhesa’s US Audit Team for a number of years and also has experience auditing sites across a large variety of industry sectors in many different parts of the Americas. Prior to taking the role of US Audit Team Lead, Jack previously managed Enhesa’s Audit Protocol service – helping to evolve and perfect Enhesa’s Audit Protocols to meet the needs of EHS auditors - bringing a unique perspective in that regard.Together, the two presenters will provide valuable in-sight into the workings of, tools used and issues faced, by corporate EHS auditors.

April 17 & 22 Enhesa Webinar: US Regulatory Global ForecastPleasejoinusforEnhesa’sAprilwebinarwherewewillfocuson theanticipatedchanges in theUnitedStatesEHSRegulatoryFramework.DrawingonourexpertiseinmonitoringEHSregulationsattheFederallevelandinthe50USstates,EnhesahasanalyzedtheproposedandpassedEHSregulationstoidentifykeytrendswhichwillimpactbusiness in thenextyear. Look for registrationinformationinyouremailinthenextcoupleofweeks.If you are not on Enhesa’s invitation list for our we-binars on EHS Issues of Relevance send an email to webinar@enhesa.com to begin receiving invitations and get access to past webinars. Upcoming 2014 webinars will include EHS Regulatory issues of interest in Eastern Europe, Latin America, the Middle East and EU, as well as on one on Product Stewardship organization and growing regulations.

In the planning (subject to change):• Product Stewardship: How to ensure that your products can be put on the market? What are the risks you face in some countries/regions? How to secure your markets by complying and forecasting environ-mental changes that target products? May 2014

• International Global Risk Management: the chal-lenges of culture, language, regulatory systems and change. in collaboration with UBM, organizers of the annual SHE Exhibition & IOSH Conference. May 2014• What’s going on in Eastern Europe? Which new key EHS regulatory developments have been adopted and are in the pipeline? June 2014• Overview of the EHS regulatory developments in Latin America. July 2014• What’s hot in the Middle East? A focus on the latest EHS regulations proposed and adopted in this region. September 2014• Is Western Europe a leader in the adoption of new EHS developments? What has been achieved and is being prepared? October 2014

Webinar@enhesa.com

ConferencesMarch 13-14, Shanghai Conference: China Environmental Health Safety and Quality Excellence SummitThe 3rd AnnualChina EHS&QExcellenceSummitwilltakeplace2014-03-13 to2014-03-14at theCrownePlazaCenturyParkHotel inShanghai,China.BringingtogetherEHS&Qindustryprofessionalsfromaroundtheworld,thismeetingseekstostrengthenattendees’un-derstanding of EHS policies and regulations in Chinawhilealsoreviewingregulatoryissuesandemergingis-suesfacingCorporateEHS&Q.Fabio Cherubini (Director of EHS Auditing Services) and Ellen Zhang (EHS Regulatory Consultant) of En-hesa will conduct a joint presentation discussing both EHS regulatory updates in the Asia-Pacific region and compliance challenges often faced due to unclear/un-defined requirements.In the next months, Enhesa will attend and participate to the following conferences:• 15th Annual Gensuite Customer Conference,

May 6-8, 2014, Cincinnati, OH• CHWMEG Tokyo, May 16• CHWMEG Shanghai, May 19-20• IOSH Annual Conference 2014, June 17-18,

London, UK

Enhesa’sWebinarsandConferenceProgram

Events

Next month, Enhesa will launch its long awaited new website. In this feature, the Enhesa Flash edi-torial team talked to Cecile Baudon, Enhesa’ Sales & Marketing Director, to get her thoughts on the new website and what it will mean for Enhesa and our clients.

Hi Cecile, I think it’s fair to say that Enhesa’s old website has been around a while, and this change has been coming…Absolutely! Let’s not talk about the old website which was conceived over a decade ago in the dark ages of the internat! As a fast-growing, client-focussed company we felt it was high-time to get our house in order. However, we wanted to get the website ab-solutely right, so we have taken the time to ensure that every aspect of it is perfect.

What has changed from the previous site?Pretty much everything, apart from the basic de-scriptions of the services we provide! We have made it generally more user-friendly, less wordy, slicker and pleasing on the eye. It should really help us to clearly convey what we do to the international EHS and Product Stewardship Managers that will access the site.

What do you see as being the main benefits to Enhesa’s clients of the new site?Enhesa’s existing clients will find it a fresh and en-gaging website to get an insight into Enhesa News and Service Developments, as well as information on other services we offer that may be of use to them. For companies who don’t yet use Enhesa, it will offer clear descriptions of how Enhesa can help them in their specific roles, or to meet their specific EHS regulatory compliance needs.

What will be the key features of the new site?We will more closely integrate our site with social media (LinkedIn, Blogs, etc); provide clear and in-teresting information about Enhesa as a company - our people and the work that we do, as well as con-tent-based articles and news items. We will have sections tailored to different types of EHS profes-sions looking for help and support in meeting their global compliance challenges – helping clients find the best fit of our services to meet their needs.

ABraveNewWorldEnhesa’s New Public Website