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WHITE PAPER IMPLEMENTING A GLOBAL APPROACH TO MANAGING EHS REGULATORY COMPLIANCE A Publication from Enhesa & Enablon

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Page 1: WHITE PAPER - Enablon® … · WHITE PAPER IMPLEMENTING A GLOBAL APPROACH TO MANAGING ... of navigating regulatory complexity, presenting a challenge on a number of levels: FIGURE

WHITE PAPERIMPLEMENTING A GLOBAL APPROACH TO MANAGING EHS REGULATORY COMPLIANCE A Publication from Enhesa & Enablon

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ABOUT THE AUTHORS

IMPLEMENTING A GLOBAL APPROACH TO MANAGING EHS REGULATORY COMPLIANCE

This publication will examine the following issues:

• The global challenges of compliance with EHS laws.• The consequences of not complying.• Why is a global approach essential?• EHS is more than just regulatory compliance.• How Enablon, partnered with Enhesa, can help address these challenges.• Practical best-practice/use-case examples of using Enhesa content in Enablon.

Implementing a Global Approach to Managing EHS Regulatory Compliance 2

Copyright © 2017 Enablon & Enhesa. All Rights Reserved

Tjeerd is Head of Thought Leadership at Enhesa, the global market leader in EHS regulatory compliance assurance services, and has over 17 years of experience as an EHS policy, regulatory and management expert with the company. In that time he has worked with corporate clients across all industries and all over the world to help them to manage their international EHS legal compliance challenges. Tjeerd has held various roles with Enhesa prior to his current role, starting out as a Regulatory Analyst, then Project Manager, before moving into Business Development and Account Management and leading the Enhesa Sales efforts outside of North America.

Jean-Grégoire Manoukian is Content Marketing Manager at Enablon. He manages Enablon Insights and the company’s social media activities, and writes about various EHS, Risk and Sustainability topics. He has more than 18 years of professional experience, including many years as a product manager for chemicals management and product stewardship solutions. He also worked in the telecommunications industry as a product marketing manager. Jean-Grégoire has dual French and Canadian citizenship, and likes to stay informed on the latest trends and developments from both sides of the Atlantic.

TABLE OF CONTENTS

The Global Challenges of Compliance with EHS Laws ........................................................................................The Consequences of Not Complying .................................................................................................................Why a Global Approach is Essential for Multinational Companies ....................................................................How do Companies Manage Compliance Globally? ........................................................................................The Rise of Integrated EHS Software Solutions .....................................................................................................Enablon and Enhesa Facilitate a Global Approach to EHS Compliance & Auditing ......................................How the Enhesa Data Feed is Used by the Enablon Platform .............................................................................Enablon Audit Management Software .................................................................................................................Enablon Regulatory Compliance Management Software ................................................................................Practical Examples of How Enhesa Content is Leveraged by the Enablon Platform .....................................Conclusion ...............................................................................................................................................................

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IMPLEMENTING A GLOBAL APPROACH TO MANAGING EHS REGULATORY COMPLIANCE

Please ask yourself the following question:

Are you currently legally compliant with all applicable EHS laws in every location where you operate?

Of course, this is an unfair question. No one can ever be 100 percent assured they comply with the hundreds, even thousands, of regulatory obligations around environment, health and safety in each of their myriad of global locations. The best-case response is likely to be “I am as confident as I can be”, the worst-case response would obviously be “I have no idea.”

This question is even more difficult due to the varying cultural, linguistic and jurisdictional factors that come into play.

In this paper we will examine the problems faced and some best-practice suggestions on how to make answering the aforementioned question that much easier.

Implementing a Global Approach to Managing EHS Regulatory Compliance 3

The Global Challenges of Compliance with EHS Laws

Compliance with the law, in any jurisdiction, is a complex and time-consuming business. Laws are constantly changing and evolving. Legal language is very often a quagmire of references, cross-references, legal phraseology and obscure definitions. This is compounded by the simple fact that laws vary per country, region or even municipal jurisdiction and of course, they are invariably not published in English.

These challenges are confirmed by a recent Enhesa (global multinational) customer survey that looked into the greatest challenges faced in terms of EHS Regulatory Compliance (See Figure 1).

The results are no surprise when you consider that in 2016 alone, Enhesa published reports on more than 4,000 EHS regulatory and policy developments in more than 270 jurisdictions (national and state level) around the world.

The volume of law, and the rate of change, is compounded by the challenge of navigating regulatory complexity, presenting a challenge on a number of levels:

FIGURE 1

• Identifying which laws apply to a given type of operation• Determining which of the specific requirements in each law concerns you (and whether

there may be exceptions)

Copyright © 2017 Enablon & Enhesa. All Rights Reserved

Keeping up with EHS regulatory changes

Managing global regulatory complexity

Lack of understanding of site-to-site regulatory obligations

Navigating languages, cultural barriers and local regulatory schemes related to EHS regulatory

compliance

Inability to assess regulatory compliance risk

Lack of confidence in internal approach to EHS compliance

Ensuring site safety and minimizing accidents

Facing increased scrutiny from regulators

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Implementing a Global Approach to Managing EHS Regulatory Compliance 4

• Navigating the complex legal language which can often be obscure, vague and peppered with cross-references either within the same law, or in different laws

• Staying on top of amendments that are not consolidated, requiring research time

Another challenge revolves around consistency and visibility of compliance across many different global locations. The law in one country (or even state/region/province within the same country) will often differ to varying degrees, making it impossible to apply global corporate-wide standards on EHS that seek to encompass all possible regulatory fluctuations. There are, of course, cases where one country applies stricter laws than another, but in many cases the requirements are simply different, often as a result of cultural and economic differences.

For example, in France (under the Labor Code, Regulatory Part, Part IV, Book VI, Title II «Occupational health services»; Art. R. 4623-32) there is an obligation for industrial facilities with more than 200 employees (and all facilities with more than 500 employees) to have at least one occupational nurse (and then additional nurses are required for different employee number thresholds). This is a requirement relatively unique to France. It is unlikely that it will be adopted as a global corporate standard in all your administrative offices of more than 500 employees, if there is no obligation to do so under the law.

The Consequences of Not Complying

As EHS has edged its way into corporate consciousness, the public’s mind and that of the regulators, the challenge to comply has never been greater and neither have the penalties for failure.

PHYSICAL HARM TO PEOPLE AND/OR THE ENVIRONMENT

Worker deaths and catastrophic environmental incidents are the most obvious and emotive reasons for acting safely and responsibly. Be it a massive mine tailings spill in Brazil1 or an industrial explosion killing at least 173 people in Tianjin, China2, compliance with EHS laws can never provide an absolute guarantee that such things will never happen because human error, force majeure and unpredictability remain constant threats. However, when such things occur, there are no winners, only massive losers. The resulting negative effects to business can also be felt for years if not decades afterwards, with production shutdowns (such as those that impacted Toyota and John Deere)3, high-profile investigations (such as those impacting BHP Billiton and Vale)4, and reactionary legislation (such as those that were adopted or being developed across Brazil)5 being covered in great depth and at great length by the media.

REGULATORY FINES

The 2016 enforcement statistics provided by the U.S. EPA illuminate a critical truth: U.S. companies are no longer exposed to court risks in the millions of dollars; environmental enforcement actions are now collecting billions of dollars6.

Copyright © 2017 Enablon & Enhesa. All Rights Reserved

1 - https://www.theguardian.com/sustainable-business/2015/nov/25/brazils-mining-tragedy-dam-preventable-disaster-samarco-vale-bhp-billiton 2 - http://time.com/3994621/explosion-tianjin/ 3 - http://www.bbc.com/news/business-339557834 - http://www.reuters.com/article/us-brazil-mining-samarco-idUSKCN114259 5 - https://www.theguardian.com/world/2015/nov/10/brazil-dam-burst-mining-rules 6 - https://www.epa.gov/enforcement/enforcement-annual-results-fiscal-year-2016 accessed on 14th April 2017

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Implementing a Global Approach to Managing EHS Regulatory Compliance 5

The fines issued by OSHA should also not be ignored. Notably, OSHA increased its fines in 2016 for the first time in more than 25 years7 which resulted in base levels of fines nearly doubling. For example, prior to the changes the penalty for a willful or repeated violation was $70,000 per violation. Following the adjustment rule, this is now $124,708 per violation.

Although the recent change in administration in the U.S.A. combined with the widely reported scale back of Federal Regulations and (up to thirty percent of) the EPA’s budget, could potentially lead to a reduction in federal enforcement, there are indications that State level enforcement and individuals, NGOs and even companies taking action to “do the right thing”, may result in continued high-levels of scrutiny on industry.

The sizable fines being imposed in the UK are also on the rise and this is expected to continue. In February 2016, new sentencing guidelines came into force in the UK under which companies could face over £10 million in costs for the most serious health and safety violations and more than £20 million for corporate manslaughter convictions8. The HSE enforcement statistics show that the largest 20 fines to businesses for health and safety violations in 2016 were three times more than the largest 20 fines in 2015 and eight times higher than in 20149.

The UK, like the U.S., has always been very active in enforcement prosecutions (and the publishing of such). In many other countries where this is much less the case, it is much harder to find concrete statistics on enforcement rates and levels of fines. This is changing though. In China for example, the Ministry of Environmental Protection now publishes monthly news articles summarizing enforcement actions that include numbers of enforcement cases as well as amounts of fines. In one recent news release on 17 April 2017, it was reported that 239 companies (out of 329 inspected in the Beijing-Tianjin-Hebei region), were to be charged with violations related to illegally producing pollutants and lacking pollutant reduction equipment10.

The (until now) relative lack of publicity around cases is not to say that there has not been any enforcement in China and other countries. Examples include the 2009 case of Jinye Company in China that was fined ¥16 million (approx. $2.3 million) for illegally discharging Arsenic in a river11. Vietnam has also seen an overhaul of its EHS laws and a resulting increase in enforcement (including a very high profile 2016 case involving Formosa Plastics, which resulted in a payment of $500 million in damages12).

CRIMINAL ENFORCEMENT

In its 2016 enforcement report, the EPA reported the imposition of 93 combined years of incarceration for sentenced defendants. Criminal enforcement around EHS management, with penal sentences for Corporate-level staff being held responsible, is also on the rise around the world.

Copyright © 2017 Enablon & Enhesa. All Rights Reserved

7 - https://www.osha.gov/Publications/OSHA3879.pdf 8 - https://www.sentencingcouncil.org.uk/wp-content/uploads/HS-offences-definitive-guideline-FINAL-web1.pdf 9 - http://www.hse.gov.uk/statistics/enforcement.htm 10 - http://english.mep.gov.cn/News_service/media_news/201704/t20170417_411614.shtml 11 - http://www.gokunming.com/en/blog/item/945/company_officials_punished_for_polluting_yangzonghai 12 - https://www.bloomberg.com/news/articles/2016-06-30/toxic-discharge-from-taiwan-s-formosa-caused-vietnam-fish-deaths

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Implementing a Global Approach to Managing EHS Regulatory Compliance 6

Other countries are also increasingly sending responsible persons to jail. A case decided in January 2017 in China highlights this, when Dystar received a penalty equivalent to $2.9 million for dumping several hundred tons of untreated liquid acid into a canal between September 2013 and May 2014. Most notably, as part of the criminal verdict, six of Dystar’s key managers were jailed for between three and half to five years13.

In the aforementioned Jinye Company case, the Company President and General Manager were also imprisoned for 3 and 4 years respectively and fined between ¥150,000 and ¥300,000.

BRAND & REPUTATION

In the last few years, high-profile public relations disasters have had long-term impacts on a number of companies, such as BP14, Volkswagen15, Glaxo Smith Kline16 and most recently, United Airlines17.

These were all examples of the speed at which an issue can become global news, permeating social media, resulting in damages to reputation, reduced sales from consumer boycotts and in each case, a startling drop in the share value of the company in question.

Enhesa’s 2017 “Cost of Compliance” Benchmarking survey found that 96 percent of companies recognize damage to reputation as a consequence of non-compliance.

EMPLOYEE CULTURE & VALUES

Another cost element that is hard to define is the impact regulatory non-compliance incidents can have on the morale of employees and the overall workplace culture. Existing employees are likely to see drops in productivity as a result of incidents that can impact physical and mental health. Talented potential future employees will also think twice about coming to work for a company that has a poor safety or environmental protection reputation. The costs of these factors are impossible to quantify, they are both short and long term and simply ignoring the issue will definitely NOT add to your company share price.

THE GLOBAL MULTIPLIER

Individual sites may have received an odd fine, a few lost-work-day incidents, or even, heaven forbid, a fatality to contend with. However, it is the cumulative effect of such incidents that can begin to impact a corporation more broadly, in terms of public perception, culture and ultimately, share price. In this context, a global view to EHS as a whole is not just a luxury, it is a necessity.

Copyright © 2017 Enablon & Enhesa. All Rights Reserved

13 - http://news.xinhuanet.com/english/2017-01/07/c_135962989.htm14 - http://marketrealist.com/2014/09/bp-lost-55-shareholder-value-deepwater-horizon-incident/ 15 - https://www.bloomberg.com/news/articles/2015-09-21/volkswagen-drops-15-after-admitting-u-s-diesel-emissions-cheat 16 - http://edition.cnn.com/2013/07/25/business/china-glaxosmithkline-bribery-corruption-scandal/index.html 17 - http://www.cnbc.com/2017/04/12/shares-of-united-fall-for-second-day-as-controversy-lingers.html

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Implementing a Global Approach to Managing EHS Regulatory Compliance 7

Why a Global Approach is Essential for Multinational Companies

There are many clear reasons for companies to adopt a global EHS regulatory compliance approach, including the following:

- Consequences are global

If your site in China has a major chemical spill, the chances are that your shareholders in New York or London will hear about it pretty quickly. Regulatory fines that are incurred at individual sites rapidly accumulate when you operate at more than, for example, 100 locations. The impacts of non-compliance can be local and direct, but the greater impact will be global.

Regulatory fines that are incurred at individual sites rapidly accumulate when you operate at more than, for example, 100 locations.

- Local does not equal consistent

Many companies out there leave it to their sites to manage EHS legal compliance locally. “They will know the local laws best” is the common phrase. However, what a decentralized, local-only approach will not do is:

• Make it easier to instill a global corporate EHS compliance culture (or even start to develop one)• Give a global, coherent and reliable view on EHS compliance performance and liabilities• Provide greater confidence in your ability to say you are compliant at any given location• Give individual site-locations the impression that compliance with EHS laws is taken seriously

across the company• Allow for comparison of compliance status throughout the organization

In addition, it is increasingly the case that enforcement authorities will consider whether a company has a consistent and effective compliance program in place when considering enforcement action or mitigation.

- Shared learning & experience

Knowledge is power. If you don’t have an adequate view of the compliance status of your locations, the recurring problematic issues, or the penalties being incurred, then it is not something that can be managed effectively. Examining weaknesses (but also strengths) across your global operations can lead to the sharing of best-practices and therefore greater compliance program efficiency and effectiveness. Positive compliance stories are a vital component to keep local teams motivated and involved. Having a common global resource and platform enables this.

- EHS increasingly informing business decisions

The recent updates to ISO 14001 and soon-to-be-published ISO 45001 have increased the focus of management systems to encourage EHS to be central to certified companies’ business strategy and core values. Environmental disasters, or major health and safety incidents elicit a reactionary response, but with EHS considerations also providing many opportunities for innovation and business sustainability, EHS is gradually climbing up the corporate strategic agenda. As policy concepts such as the circular economy and CSR reporting become more widespread, this will also increase EHS management, which will provide a definite competitive advantage.

Copyright © 2017 Enablon & Enhesa. All Rights Reserved

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Implementing a Global Approach to Managing EHS Regulatory Compliance 8

- Today, companies can go global

For a long time, there were many companies who simply did not consider the possibility of a global EHS compliance system, due to the scale of the task of tracking EHS laws (which constantly change) all over the world, which is immense and would require a lot of resources. Not all are there yet, but corporate EHS teams have come to realize that there are now services and software tools out there that make a global approach to ensuring and managing compliance possible.

How do Companies Manage Compliance Globally?

The reasons for a global EHS compliance program are clear. But how can this be achieved?

Enhesa has worked with companies managing (and implementing) global EHS compliance programs for more than 25 years. Based on our experience, we would say that there are five common denominators for best-practice:

1. Lead from the top

2. Involve everyone

3. Speak everyone’s language

4. Support, train and inform

5. Choose the right tools and services

The desire and need for a global approach needs to come from the top management of the company. Without corporate buy-in and commitment, a global approach will not happen.

The desire and need for a global approach needs to come from the top management of the company. Without corporate buy-in and commitment, a global approach will not happen.

Of course, a global outlook for corporate EHS regulatory compliance does not mean taking responsibility away from local site knowledge and expertise. Far from it. In general, by setting the tone, the standards and the priorities, a corporate EHS function guides, inspires and gives more weight and ownership to on-site personnel working in the field.

If I, as a plant EHS manager, feel my corporate heads are watching out for me, giving me the structures and financial support that I need to do my job (including services I can use in my own native language as well as English), I will feel more valued and will perform better. In turn, if I support my global and regional EHS structure through measuring, calculating and reporting on my local EHS performance and challenges, I am directly inputting into the corporate strategy and directly influencing the safe-working and environmentally-conscious practices of my colleagues around the world.

The approach is also backed up by evidence from Enhesa customers, which demonstrates how different levels within an EHS management structure use EHS compliance program services (See Figure 2).

Copyright © 2017 Enablon & Enhesa. All Rights Reserved

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Implementing a Global Approach to Managing EHS Regulatory Compliance 9

FIGURE 2

When involving everyone in the company and selecting the right tools and services, the following are essential to help to achieve EHS compliance:

• Global coverage – apply a consistent service across all of your sites• Enable (or support) simple filtering of which laws and requirements are applicable• Ensure that regulatory compliance information provided is clear, and has suitable guidance• Provide tools, information and training both in English but also (and often more importantly)

in the local language of the in-country users• Make sure you have a regulatory support service from EHS regulatory experts from the

countries in question• A standardized, easy-to-use interface with the necessary level of details for different user

levels• Frequent updates, with changes clearly indicated and notified

Global or corporate EHS management teams

Regional EHS team

Local site users

Audit team

Local offices

Product management team

Who utilizes Enhesa’s services at your organization?

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Copyright © 2017 Enablon & Enhesa. All Rights Reserved

Implementing a Global Approach to Managing EHS Regulatory Compliance 10

Global EHS Management is More Than Just Regulatory Compliance – The Rise of Integrated EHS Software Solutions

EHS is a very broad topic. As well as legal compliance, it encompasses CSR reporting, incident and accident tracking, air and water emissions recording and reporting, energy use monitoring, etc.

In addition, the (friendly) tentacles of EHS now increasingly spread into the realms of Legal, HR, Process Safety, Quality, Product Development, Chemicals Management, Facilities Management, Contractor Management, Occupational Health, etc. It is an enterprise-wide issue. It goes without saying that the tools needed to handle all of these aspects should also be company-wide. The different elements need to talk to each other.

This need and the recognition is what has spawned the rapid rise of integrated EHS software management tools, such as Enablon, in recent years. Enhesa recognized this trend and established a strong global partnership with Enablon to ensure that mutual clients make the most of their respective strengths and have what they need for a truly global compliance approach.

Enhesa is able to automatically feed its EHS regulatory compliance intelligence to the Enablon Audit Management or Compliance Management applications.

This means that legal compliance and the management of compliance for your management system can nowadays be managed centrally, from the corporate level and all the way down, alongside all the other vital elements of an EHS program.

Enablon and Enhesa Facilitate a Global Approach to EHS Compliance & Auditing

By leveraging a world-class platform such as Enablon, with the regulatory analysis of EHS regulations covering all your global locations (often referred to as “regulatory content”) you’ll be able to ensure compliance, minimize risks and improve profitability across your organization.

How the Enhesa Data Feed is Used by the Enablon Platform

Enablon clients use the data feed of the Enhesa regulatory content to support many different types of use cases designed to ensure compliance with regulations. Enhesa regulatory content (which includes the titles and summaries of EHS laws and regulations, applicability screening questions, auditable requirements derived from regulations as well as regulatory forecasting and frequent updates) in English and local languages, is integrated in the Enablon platform and two options are available for the regulatory content integration:

1. Manual Import: Enhesa provides an XML file directly to the client and the client imports the XML file into the Enablon platform.

2. Web Service Update: This is the ideal method to update regulatory content seamlessly and automatically. Content is updated by a single click of a button.

Specifically, the Enhesa regulatory content data feed connects with Enablon’s Audit Management and Regulatory Compliance applications.

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Implementing a Global Approach to Managing EHS Regulatory Compliance 11

Enablon Audit Management Software

The Enablon Audit Management application helps to ensure compliance with applicable regulations and to manage risk. It enables companies to deploy standardized audits, self-assessments and inspections to entities around the world, facilitating a truly global approach. The application enhances the productivity of auditors and audit program managers while providing organizations a clear measurement of their level of compliance.

Based on rules defined by the company and the risks identified at facilities, an audit plan is created. Finalized audits can be given a score and based on the risk score of the facility, the scheduling of the audit can be modified.

Checklist questions can be manually created or imported from Enhesa. During an audit, users have the capability to change deployed assessments and questions, as well as use guidance materials in place to help while answering an audit question in the mobile application.

The audit questionnaire can link directly to a regulation, permit or policy within the Regulatory Compliance Management application with any resulting findings or issues discovered through the course of the audit generating a notification to applicable users of the potential noncompliance issue. The findings from the audit can include a root cause analysis and risk ranking and be launched into the Enablon Action Plan application to address and close any findings or issues.

Enablon Regulatory Compliance Management Software

The Enablon Regulatory Compliance Management application is especially well suited for large, global companies with multiple geographic locations that need to keep track of ever-changing regulatory obligations to ensure compliance. It enables companies to understand what regulations, permitting requirements, policies and obligations are applicable to them globally or at the site level and develop a Compliance Register for each location. The application helps to manage changes to regulations, thus contributing to eliminating compliance deviations and non-compliance or enforcement risks. Any compliance action can generate a compliance task to document and assign the actions for timely follow-up.

The Regulatory Compliance Management application is integrated with the Audit Management application to allow companies to perform audits based on auditing protocols for applicable regulatory citations, as well as other company or ISO standards. A compliance calendar can also be used to view and track resulting action due dates and completion. The application also integrates with the Enablon Management of Change application to help users better understand changes between different versions of regulations and regulatory obligations, impacts of those changes, and what needs to be done to verify and continue to ensure compliance.

Content from Enhesa in English and local languages, covering global, federal and state/regional regulations around the world, can be integrated with the Regulatory Compliance Management application and the update process of managing new regulations or changes is fully automated. Extra information on regulations is also available through direct links to the Enhesa website inside the application. In addition, local regulations, permits, policies and standards can be added by companies to match specific internal needs. The scope of these content additions can also be specified (e.g. geographic area, individual site, etc.).

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Implementing a Global Approach to Managing EHS Regulatory Compliance 12

Practical Examples of How Enhesa Content is Leveraged by the Enablon Platform

EHS AUDIT CHECKLISTSUsers can manage audit checklists in several ways. Checklists can be manually created by users and also imported in bulk. EHS managers can import and update checklist content provided by Enhesa, by initiating a web service request. During an audit, users have the capability to change deployed assessments and questions, as well as use guides to help while answering an audit question in the mobile application.

Specifically, when a company is using audit protocols provided by Enhesa, as part of their preparations for the next set of annual audits, a user updates thousands of questions by requesting an update from Enhesa through the Internet at the push of a button. New content from Enhesa can be brought in on a regular basis. If the company needs help determining which audit protocols or questions are required, the audit protocol questions can be generated from regulatory compliance requirements already indicated as applicable for the company in the Enablon system.

COMPLIANCE WITH SAFETY REGULATIONS

Enablon customers that have implemented safety-specific software applications also rely on the Regulatory Compliance Management application to manage global compliance requirements and processes. Content from Enhesa is integrated in the application and the update process of managing new regulations or changes is fully automated so that a change appears seamlessly in the application ready for a safety or compliance manager to execute. In addition, local regulations, permits, safety policies and standards can be added by the customer. Here’s an example of the integration:

1. An injury occurs in the U.S. that is reportable in line with OSHA’s Recordkeeping Rule. Once the injury impact is saved, the event is flagged as ‘Reportable to OSHA’; with details on what sort of report to use and dates by when it is due, accessible on the list view.

2. For an impact type (e.g. injury, fire, chemical leak) that meets certain compliance conditions, compliance tasks and subtasks are automatically generated to help mitigate the risk of non-compliance related to the impact. This flags the event immediately to a compliance manager so they can take swift corrective/preventive action. All of this is triggered automatically if there is a regulation with associated compliance tasks assigned to the same location as the location of the event.

A good example of this is a worker being injured in a Confined Space, due to failure of an early warning system associated with the OSHA confined space regulation, 29 CFR 1910.146. This would be a corrective action that a compliance manager would need to ensure is in place before allowing any additional work to be done in that area.

AIR EMISSIONS REGULATORY REPORTS

The following reports and standard content for air emissions regulatory reporting are available out-of-the-box in Enablon: Part 98 (GHG) Subparts A and C, and EPA AP 42 Chapter 7 Tanks calculations. The Enablon Air Quality Management application is fully integrated with the Regulatory Compliance Management application with which content from Enhesa can cover almost all Federal and state/regional regulations around the world. Local regulations and permits can also be added.

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Implementing a Global Approach to Managing EHS Regulatory Compliance 13

Actual emissions, PTE emissions, forecasted emissions, and event emissions can all be calculated. Emissions from GHGs, CACs, HAPs, VOCs, Ozone Season and other programs are being calculated by customers through the Enablon platform. It is specifically being used in the U.S. for GHG MRR, NSPS, NESHAP, CAA, NSR, PSD, leak and event emission calculations.

COMPLIANCE WITH HAZARDOUS WASTE REGULATIONS

The Enablon Waste Management application is fully integrated with the Regulatory Compliance Management application with which content from Enhesa can cover almost all Federal and state/regional regulations around the world. Local regulations and permits can also be added. Examples of supported regulations include:

• Superfund Amendments and Reauthorization Act (SARA) 313 Toxic Release Inventory• Resource Conservation and Recovery Act (RCRA)• National Pollution Release Inventory (NPRI) (Canada)• National Pollutant Inventory (NPI) (Australia)• Environment Code (France)• Waste Directives (Europe: Council Directive 91/689/EEC of 12 December 1991 on hazardous

waste)

Conclusion

Compliance obligations are inevitable, regardless of financial performance or prevailing economic conditions. Even if a company is struggling to be profitable or parts of the world are experiencing major economic downturns, the costs of ignoring compliance obligations (fines, production delays, loss of market access, reputational impacts, etc.) are too high to ignore, which is why there is a strong business case to invest in regulatory content and an enterprise EHS platform.

But there is an additional benefit to implementing a global approach to managing EHS regulatory compliance besides avoiding the negative consequences of non-compliance. To successfully achieve compliance, you must also improve operating procedures and management systems, in addition to investing in regulatory content and an enterprise EHS platform. These improvements in processes, procedures and management systems produce positive impacts on others areas also, such as the safety culture, process safety management, environmental performance, corporate social responsibility, operational excellence, etc.

Therefore, implementing a global approach to managing EHS regulatory compliance is not just about compliance, it is also about improving your organization holistically and making day-to-day tasks and operations more efficient. Contact Enablon and Enhesa to learn more and to start your journey towards compliance excellence and enhanced business performance.

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Enablon, a Wolters Kluwer business, is the world’s leading enterprise provider of EH&S, Risk and Sustainability Management Software. More than 1,000 global companies and 1 million users rely on Enablon software solutions to manage their environmental and social performance, minimize risks and improve profitability.

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Enhesa helps global multinational companies be compliant with, and stay on top of, Environmental, Health & Safety (EHS) Regulations wherever they operate. Enhesa’s in-house team of multilingual regulatory analysts provide clear, concise and standardized content and insight on current and future EHS regulatory obligations in over 270 jurisdictions worldwide. Enhesa’s Compliance Intelligence and Regulatory Forecaster services can be provided as an automated datafeed - integrated with the world’s leading EHS software platforms. Enhesa has offices in Brussels, Washington DC and Tokyo.

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