Do your “low risk” facilities get enough attention?

On two occasions now in the past few years I have been sitting in a meeting room with client prospects (mainly senior or corporate EHS managers around the world), and the fire alarm has sounded. On the first occasion, my hosts and I went to exit the nearest marked fire exit, only to find it was padlocked shut, from the outside. Luckily it was only a drill. On the second occasion, our meeting kept on going; the alarm (still ringing in our ears) dismissed by my hosts as “just testing the alarms” and we would not have to move. After 10 minutes of this, there was a realization that actually, maybe this wasn’t a test, or a drill. It was neither. We were lucky again that the fire was in another part of the office block. Both the aforementioned prospects did become clients!

I have heard several similar stories from contacts around the world; the rope ladder fire escape on the 5th floor of an office block in Cairo, that only reached down to the 2nd floor, being one such good example.

It seems logical that offices (and to a certain extent retail, service centres, datacentres and warehouses) are often seen as “low-risk” type operations compared to industrial/manufacturing sites. It is therefore understandable that companies tend to focus their time and budgets on their greatest risks. However, be very careful not to take you eye off the “low-risk” ball. We have seen growing evidence of enforcement cases (in the UK and US particularly) relating to such locations; the numbers of ergonomics-related injuries (often associated with desk work) continue to be high; and in our experience the rates of non-compliance with legal requirements can be just as high as for higher-risk operations.

In 2013 Enhesa carried out more than 80 EHS compliance audits at office-based facilities in more than 20 countries around the world. You may be surprised to hear that on average we audited against 255 applicable legal requirements per country. Although this is typically around 40% less than the requirement faced by industrial manufacturing sites, it is still a significant amount of EHS legal obligations your “low risk” sites generally have to contend with. Of equal note is the fact that we found an average of 13% non-compliances against these requirements (in fact, we found an average of 23% non-compliance in Asia compared to Europe at 9% and the America’s at 10%). Most of these non-compliances tend to be in relation to fire safety; risk assessments and ergonomics issues. Perhaps most interesting of all, this is pretty much in line with the percentage that we find in manufacturing facilities. So whereas there may indeed be somewhat fewer requirements to meet, and perceptions of risk are lower, in our experience this does not mean that office sites are any more compliant than industrial sites.

In our experience there are a whole variety of factors at play as to why companies struggle to meet their compliance obligations: who is responsible (landlord or tenant)? What are the specific local requirements? Unusual local requirements can also catch you off guard. For example, In India businesses must keep equipment on site for the treatment of persons with electrical shock, such as wooden sticks to remove the person from the source of the shock.

The moral of the story is clear. Offices are as much a part of your EH&S remit as your factories.

Tjeerd Hendel-Blackford

Enhesa will be sponsoring the global risk management track at the IOSH Conference in June. The Conference Track will include a roundtable discussion focussing on the low vs high-risk H&S challenges.

– Blog originally posted at:“low-risk”-facilities-get-enough-attention-#sthash.71lCt8YQ.dpuf


We should respect the local laws of non-EU countries – no matter how ridiculous they might seem

Anyone who has worked for an international company will likely have a fair few cross-cultural stories to tell. I for one hear anecdotes on different cultural approaches and requirements relating to environment and health and safety issues on an almost daily basis. Some of these anecdotes stem from unusual legal obligations that we cover for our clients. They can raise a few eyebrows to those of us brought up on EU-led safety-consciousness.

For example, did you know that in India, under the Factories Act 1948, there is a requirement that only adult male workers wearing tight-fitting clothing can examine, lubricate or adjust any machinery in motion? Or that in Russia, under a 2009 order, if you work in an environment where you may be exposed to ionising radiation, you are entitled to regular provisions of free milk? Were you aware that in Pakistan certain factories are required to provide spittoons at convenient places for their workers?

Of course, although these requirements stand out as being unusual – even humorous – they pertain 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 workfloor? Being aware (or unaware) of local legal obligations are just one of a variety of risks that your company will face when doing business, and keeping your people safe and healthy, wherever you have locations around the world. As well as variations in law, you will of course also have to contend with differences in culture, language, professional approaches, customs, holidays and religious festivals, beliefs and attitudes. All of these factors must be considered when trying to manage safety in different locations.

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 easy to tell your site in France, China, 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 management in the UK that is more developed (or perceived to be more developed) than in some countries, but our research at Enhesa is also finding an exponential rise in the adoption of EHS laws and enforcement of these around the world.

Governments 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 a session on global risk management at the IOSH conference in June 2014.

Tjeerd Hendel-Blackford, Business Development Manager EMEA


Originally published at:–-no-matter-how-ridiculous-they-might-seem#sthash.51bRA3qs.dpuf

Global Compliance Challenges in “Low Risk” Environments – Free Webinar!



Tuesday, November 5 at 10:00 AM EST (New York Time)

Thursday, November 7 at 9:00 AM EST (New York Time)

Are you aware of the health and safety regulations impacting your offices, retail stores, warehouses, or other non-manufacturing facilities?  
Have you kept track of the recent enforcement activities associated with office compliance transgressions?  
Do you have policies and procedures in place to deal with infractions or accidents in non-manufacturing locations?

EHS Managers and Practitioners all around the world are seeing heightened activity surrounding office and retail regulation. However, due to the common understanding that offices, warehouses and retail spaces are “low risk” compared to manufacturing or production sites, many companies don’t allocate enough resources to ensure compliance with EHS law in these environments.

Health and safety incidents still occur in non-manufacturing sites and many countries are increasing their regulatory attention and enforcement practices in this area.  Best-in-class companies know it is an area that demands a compliance process, but one that is different than that used for manufacturing sites.

Drawing on Enhesa’s auditing experiences and expertise with regard to non-manufacturing compliance, this webinar, held on  5 November at 10:00 AM EST and  7 November at 9:00 AM EST, Enhesa will explore:

  • Perceptions and concerns of EHS Managers on non-manufacturing compliance
  • Key differences between auditing a non-manufacturing facility versus an industrial site
  • Identification of common high risk non-compliance issues with examples of enforcement cases
  • EHS issues, notable requirements and challenges
  • Solutions to managing EHS compliance in non-manufacturing facilities – including a presentation by guest speaker and EHS Leader for Europe, Russia and Germany, Peter Tayar-Watson, on GE Global Operations Properties’ non-manufacturing compliance

We hope you’ll join us!

The Enhesa Team


537Peter J. Tayar-Watson, BEng CEng MBA
EHS Leader Europe-Russia-Germany
GE Global Operations Properties

Peter is the EHS Leader for Europe, the Middle East & Africa at GE Real Estate and is based in London, UK. Peter has a Bachelor’s degree in Mechanical Engineering and Business Studies, an MBA from the NIMBAS School of Management, and is also a UK Chartered Mechanical Engineer (IMechE). Over the years, Peter has worked for Shell Petroleum in the Netherlands as a Project Engineer on Gas Development projects, including safety & environmental permits & studies. He was later transferred by Shell to Gabon, West Africa, where he worked for 3 years in contracts & procurement and later as a Project Manager for a USD multi-million environmental remediation project.

Peter moved to General Electric in The Netherlands with GE Energy in 1999 as European Service Depot EHS Manager. During this role he led the site to achieve the Global Star award for Health & Safety, the global GE Energy Quality award, and external certification for quality (ISO9001) and safety management systems (VCA). In 2005, Peter relocated to the United Kingdom to work with GE Corporate Properties, his current role. He now manages EHS Compliance and risk across 75 locations over 40 countries in EMEA, and manages approximately 40 projects at any given time.

498Tjeerd Hendel-Blackford
Programme and Business Development Manager

Tjeerd Hendel-Blackford is a Programme and Business Development Manager with Enhesa. He has over 10 years of experience as an EHS policy, regulatory  and management expert. Tjeerd holds law degressfrom the University of Warwick in the UK, and the College of Europe in Bruges, Belgium. In addition Tjeerd holds graduate membership of the Institute of Occupational Safety & Health (IOSH) and is an Associate member of the Institute of Environmental Management & Assessment (IEMA). Tjeerd speaks English, Dutch and French.