ehs compliance in china
Post on 23-Jan-2018
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EHS Trends, Legal Updates and Lessons
Learned and Audit Integration
帮助企业遵循EHS质量要求将世界变得更美好
Improve the world by helping businesses comply
to environmental, health and safety and quality
requirements.
1. Top regulatory updates 2. Lessons learned tracking compliance 3. Effectively manage a 14001 register 4. Link EHS Audits to Changing Regulations
• Minamata Convention on Mercury Enters into Force
• Kenya Health Act Requires Lactation Rooms in the Workplace
• EU: Regulation Setting a Framework for Energy Labelling
• New Law on REACH (KKDIK) Issued in Turkey
International, EU and Africa
• Law Enacted to Protect Worker Safety and Health in Emergencies in Chile
• Canada Bill on labelling toxic products
• British Columbia : New spill response rules in effect soon
• US Delays and Excludes a series of requirments
Americas
• Measures for the Supervision and Administration of “Three Simultaneities” of Facilities for the Prevention and Control of Occupational Diseases of Construction Projects
• Regulations on the Administration of Construction Project Environmental Protection
• Less upfront paperwork, more fines.
China
Automotive Safety Changes
Regulatory Approval for Oil & Gas Pipelines
Great ISO 14001 Legal Registers
Nimonik Jonathan Brun, CEO
• A framework to follow
• Built on best practices and industry knowledge
• Your clients force you to do it
Why management standards?
• Certification requires it
• All companies are subject to the law
• Ignorance does not hold up in court
Why legal register?
• The organization shall establish, implement and maintain a procedure(s)
• to identify and have access to the applicable legal requirements and other requirements to which the organization subscribes related to its environmental aspects, and
• to determine how these requirements apply to its environmental aspects.
• The organization shall ensure that these applicable legal requirements and other requirements to which the organization subscribes are taken into account in establishing, implementing and maintaining its environmental management system.
14001:2004 4.3.2
6. Planning
• 6.1 Formulate actions to address your risks and opportunities.
• 6.1.1 Develop processes and prepare plans to establish EMS.
• 6.1.2 Identify significant environmental aspects and impacts.
• 6.1.3 Study environmental aspects and compliance obligations.
• 6.1.4 Address aspects, obligations, risks, and opportunities.
ISO 14001:2015 6
Compliance obligation
“A compliance obligation is a requirement. There are two kinds of compliance obligations: mandatory compliance obligations and voluntary compliance obligations. Mandatory compliance obligations include laws and regulations while voluntary compliance obligations include contractual commitments, community and industry standards, ethical codes of conduct, and good governance guidelines. A voluntary obligation becomes mandatory once you decide to comply with it.” - Praxiom Consulting
ISO 14001:2015 6.1.3
What are the operational requirements in terms of
permits?
What are the operational requirements in terms of
applicable rules?
What are the operational requirements in terms of
collaborative agreements?
Monitoring Programs NPRI Report Training and Employment
Incident Follow-up Business Opportunities
Expiration Date on TDG Training
Education Awards and Scholarships
Air Emissions Criteria Environmental Matters and Closure
Financial Matter
Legislation Name
Only Common Element!
• Legislation Name
• Control Measures
• Jurisdiction
• Last Revision Date
• Aspects
• Work Area or Impacted Area
Better Common Elements
• Summary of requirement
• Sections or articles (specific obligations)
• Applicability text
• Issuing authority
• Last revision person or group
• Specific hazard or asset
Additional Elements
Ideally each business activity has identified applicable environmental law by
• Aspect (i.e. Air, Waste, Water,…) and with
• Applicability Text - short and sweet.
Links to Activities
• Can a new employee read it and take action?
• Can a new employee understand the critical environmental legislation and how it applies to your operations in under 8 hours?
Actionable
• Living document vs. point in time picture
• Ability to convert your legal register into an audit protocol
Convert to Audit
SpecificBroad
Word/Excel
Software
High Cost High Value
Low Cost Low Value
Maintainability
Very Low Cost Low Value
Low Cost High Value
• Know your compliance obligations
• Link to your business activities
• Demonstrate efforts to stay compliant
• Transferability to new employees
Conclusion
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