Global expansion can open up big possibilities for an organization, but for an OSH manager, it can also be overwhelming. Managing widely disparate regulations, working with different regulating bodies, and navigating unfamiliar cultures can create roadblocks to a successful health and safety program.
Based on our global compliance experience, Antea Group can offer a glimpse into the various regulations you might encounter globally, as well as tips for avoiding common pitfalls. In particular, we’ll look at ergonomics, risk assessments, psychosocial stress, and occupational health. (NOTE: all regulations are accurate as of July 2019, but always make sure to do your own research and assessment.)
Common components of an ergonomics program include written programs, assessments, training, and medical concerns (such as pregnancy or eye exams). But, when multiplied by various geographies, those components can become pretty complex. For example, Ireland requires an in-person assessment by a qualified person for every new hire that uses a computer and mandates that ergonomics training for computer work also has to be done in-person. In California, if two employees have a diagnosed work-related repetitive motion injury in the last 12 months, the company is required by law to have an ergonomics program in place. Brazilian employers must ensure work stations are adjustable and “comfortable,” as well as complete mandatory light level sampling.
Top Tips: Watch for cultural differences that can trip you up, especially employees who might be uncomfortable voicing problems or who have a general lack of familiarity with ergonomics concepts. You will also need to consider what approach you want to take to ergonomics overall—will you be proactive or reactive? Will you meet requirements locally only, or try to standardize an approach across all geographies?
While risk assessments generally all include data and rankings for risk severity and frequency, there is a lot of room for variation in where to assess, how, and how often. For example, in Spain, risk assessments must be done by role and provided by a qualified company. The organization then must implement these recommendations and update the assessment annually and any time injuries occur. Singapore has very explicit risk assessment requirements and specifies the penalties employers could face for failure to comply—including prison. Australia requires assessments for high-risk activities such as live electrical work, but waives requirements for activities that have well-known, effective controls in place.
Top Tips: Emerging trends include requiring risk assessments for lone workers or home-based workers (Germany, Brazil) and requiring highly specific assessments, such as fire risk assessments in Ireland, or display screen equipment risk assessments in Hong Kong.
Psychosocial risk is becoming an OSH priority globally and concerns the mental, physical, and social health of employees, focusing on their actual well-being instead of merely the absence of injury or disease. However, countries and regions are interpreting this very differently in practice. In Colombia, for example, employers are required to have a dedicated committee for preventing workplace harassment, regardless of organizational headcount. Chile mandates an employee survey conducted by a certified third-party company as part of seven distinct compliance activities. Belgium requires organizations with 50+ employees to have a “Committee of Prevention and Protection at Work” and appoint a confidential counselor to act as a Prevention Advisor.
Top Tips: Make sure to fully consider how Human Resources (HR) fits in and how best to work together, as psychosocial issues impact both functions. You will also need to be prepared to address confidentiality issues, including implications from the recent GDPR legislation. It’s also important to know that as rules and regulations around psychosocial stress are still evolving, enforcement is unclear and can be ambiguous.
Occupational health may be the trickiest part of OSH due to a lack of a common definition. Depending on who you ask, it can include medical exams and surveillance, workers’ compensation, employee wellness, health benefits, return-to-work designations, and more. It also touches many different functions within an organization—HR, payroll, OSH, risk management—but is not clearly controlled by any of them.
Some example requirements we’ve seen include the Netherlands, where absentee counseling, occupational health exams, and government reporting are all required. In Japan, employers with 50+ employees must appoint an industrial doctor, establish a monthly health committee, and conduct annual mental stress checks. Italy requires that an occupational doctor be appointed to conduct a medical surveillance program and has differing medical exam requirements based on employee age.
Top Tips: Building a strong, cross-functional team is going to be critical, and often OSH is well-positioned to take the lead as the function most in tune with the risks of noncompliance. Creating and sharing common definitions is important, as is deciding whether to manage occupational health at the site, regional, or corporate level. Be prepared for leadership based in the U.S. in particular to be confused by occupational health, as global definitions and norms may be very different than what they are familiar with.
A Journey of a Thousand Miles…
While all of this variation and change can seem insurmountable, there is hope. Every global organization is struggling with these same issues—you are not alone! By remaining focused on doing right by your employees, committing to continuous improvement, and understanding your risks, you will be in a solid position. Define your company’s risk tolerance, address concerns promptly as they arise, and keep working to educate your leadership on the realities of global OSH today. You can make progress towards total compliance and, in the process, make a real difference to your employees as well, wherever they are based.
Feeling overwhelmed? Our experts can help support your global EHS needs. Contact us today to talk more!
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