International EHS flashpoints
June 4, 2008
A former Secretary of Defense once famously said: “There are known unknowns. That is to say, we know there are some things we do not know. But there are also unknown unknowns, the ones we don't know we don't know.”
For many safety and health pros here in the U.S., I believe a growing list of “unknown unknowns” may be contributing to gaps in their knowledge of important trends and in the application of effective approaches to improving workplace safety and health.
The fact is much of the rest of the developed and developing world has “caught up” and in some cases surpassed the U.S. in implementing new ideas, fresh approaches and creative strategies for improving worker safety and health.
In addition, as safety and health regulatory activity in the U.S. has slowed in the past decade, the pace of new regulation in other regions of the world has accelerated and is becoming a significant driver for the rapidly increasing number of U.S. companies doing business around the world.
In working with many of the world’s leading corporations, ORC Worldwide’s consultants are immersed in some of the key safety and health developments around the globe. Here we present information on four important initiatives we believe you should know about, either because these issues soon will have a significant impact on how key aspects of U.S. worker safety are managed, or because they are a potential source of good information on emerging safety and health issues.
1) REACH: What you need to know now
The European Union legislation on the Registration, Evaluation, Authorization and Restriction of CHemicals (REACH) took effect June 1, 2007. It potentially affects any U.S. business manufacturing or importing chemicals into the EU and will present deadlines for industry’s chemical and information management that extend for the next ten years. Missing a deadline or a failure of each manufacturing site (legal entity) to file the proper registration for the chemicals in company products could close the EU marketplace to those products.
“Pre-registration” is the first mandatory action for chemicals contained in EU products; the window of opportunity for pre-registration is June 1 to December 31, according to ORC Consultant Cord Jones and June Bolstridge, president of GAIA Corporation and an expert who works with ORC’s Corporate Environmental and European Union Forums.
Without a pre-registration, the deadline for submitting complete hazard and risk data on the chemical cannot be delayed further into the ten-year period, and industry becomes responsible for submitting an extensive dossier of information prior to marketing any products, including mixtures and articles, that contain the chemical. REACH will present industry with additional deadlines (Nov. 30, 2010; May 31, 2013; May 31, 2018) for chemical and information management over the next ten years, depending on the tonnage band and the hazardous properties of the chemicals/substances. Missing a deadline or a failure of each manufacturing site to file the proper registration for the chemicals in company products could close the EU marketplace to those products.
Extensive guidance documents are being developed by the European Chemicals Agency (ECHA) to assist industry in meeting the REACH requirements. The Agency’s web site (http://echa.europa.eu/pre-registration_en.asp) contains extensive information on REACH, pre-registration, and classification of chemicals.
Editor’s Note: ISHN will provide more detailed information on how to prepare for REACH in a future column authored by ORC Worldwide
2) GHS: Coming soon to a workplace near you
The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is a United Nations-approved approach to standardizing the definitions of chemical hazards, and communicating this information through uniform labels and safety data sheets.
ORC Worldwide Senior Consultant Ann Brockhaus has been following this issue closely. “Most countries, including the U.S.,” she says, “are taking steps to make their regulations consistent with the GHS within the next few years.”
All U.S. companies that manufacture or use chemical substances will be affected by planned changes to OSHA’s Hazard Communication Standard (HCS) so that it is consistent with GHS. The primary impact of revising the HCS, according to Ms. Brockhaus: producers of hazardous chemicals will likely be required to review the classifications of hazardous chemicals, as well as prepare and distribute new labels and revised safety data sheets.
In workplaces where chemicals are used but not produced, the most important change will be the need for employers to ensure that they and their employees understand the new pictograms and other information provided on the chemicals.
Information about the GHS can be found on OSHA’s website at http://www.osha.gov/SLTC/hazardcommunications/global.html
3 Get to know Bilbao
“One of the main resources for health and safety professionals working in Europe and throughout the world,” says Cord Jones, director of ORC’s EU Forum, “is the European Agency for Safety & Health at Work, located in Bilbao, Spain.”
This agency is a tripartite organization that works with employers, governments, and labor groups. It is a single reference point for useful information, new research and data on risks, as well as best practices. The agency explains European occupational safety and health legislation, and is home to the European Risk Observatory. The observatory provides an overview of health at work in Europe; a description of the trends and underlying factors; a description of risk factors; and anticipates changes in work and their likely consequences on health.
The agency’s Web site address is: http://osha.europa.eu/index_html
4) Reducing stress, improving well-being
“Interest in the links between how work is organized (and the stress possibly produced) and employee health has been growing, especially outside the U.S.,” says Brockhaus.
The EU’s “Expert Forecast on Emerging Psychosocial Risks Related to Occupational Safety and Health,” published last fall notes: “In 2005, more than 20 percent of workers from the EU believed that their health is at risk because of work-related stress.”
In the U.S., NIOSH has also developed a framework for understanding the impact of so-called “work organization” on employee well-being. Work organization is a broad area and impinges on related issues such as: work-life balance/flexibility, depression/psychological illness, workplace violence, older workers, and minority worker health.
The NIOSH Work Organization and Stress-Related Disorders page can be found at http://www.cdc.gov/niosh/programs/workorg/default.html
The EU Agency for Safety and Health at Work’s “Good Safety and Health Practice with Regard to Workplace Stress” can be found at: http://osha.europa.eu/good_practice/topics/stress
American companies large and small compete in the global marketplace. Increasingly, we find the safety and health agenda is being set outside the U.S. in ways that may ultimately affect all American businesses. For example, GHS began outside the U.S., but is now leading to changes in OSHA rules.
REACH regulations can affect almost any company with any business connection with Europe today. But even companies without any direct European links may find the chemical hazard information REACH provides very useful.
ORC members keep a close eye on international initiatives not just because ignoring international trends could hurt their organizations, but more importantly to help them do a better job at what matters most of all: continuously improving employee health and safety.