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April 9, 2014

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Europe vs US: different mindsets

 

Tjeerd Hendel-Blackford, Enhesa

Enhesa managing director Theirry Dumortier will speak about managing risk in the global marketplace at the IOSH Conference

I have heard the same story several times€ᆭEHS Managers over here in Europe, working for a large American company being faced with a whole raft of “corporate requirements” from head office, that presume we all live by US laws and regulations. For many it is a struggle to explain that things are done slightly differently on this side of the pond.

We at Enhesa have actually had to adapt our business because of this different approach. Although we are a Belgian-headquartered company for many years the majority of our clients have been US-based multinationals. This in fact led to us opening an office in Washington DC a number of years ago. This market demand has been due to the creation, and gradual development, over the last few decades, of an approach towards managing EHS at the US-corporate level, focused on compliance: Legal compliance.

Anyone who’s heard the (probably false) anecdote about the American who tried to dry his wet dog in the microwave€ᆭand ended up suing the microwave manufacturer for not making it clear enough that microwaves are not for dog-drying will understand why. America is renowned for its litigation happy culture. This in some way, has fuelled and forged the development of EHS management in the US which is very compliance focused. Managers in America want (need!) to ensure that they are in compliance. They don’t want lawyers or the authorities knocking on their door if something goes wrong — and especially not when the non-compliance fines are so high compared to the rest of the world.

Of course, in Europe, we also don’t want our doors knocked on by fine-wielding inspectors. But in Europe the story is different. EHS managers will tend to have lower budgets than their US counterparts and take a different, more dialogue-based approach to non-compliance findings. People often get a chance to respond to and correct issues, which is not an approach recognized in the States. As a result the services we sell to US clients, versus those we sell to companies in the rest of the world are noticeably different. US companies tend to veer towards our EHS compliance scorecards or checklists. In Europe this service is also popular, but clients tend to also want a more Management System “legal register” type approach.

It will be interesting to see how, with the revisions undertaken to all ISO Standards, the on-going review of ISO 14001 and the imminent creation of ISO 45001 to replace OHSAS 18001 these different approaches will be impacted. US companies are less inclined to go for these management systems. This is a fact backed up by numbers€ᆭin 2012 just under 6,000 ISO 14001 certificates were held in the US, compared to over 15,000 in the UK and over 90,000 in China.

However, what we hear about the new and revised versions of the EHS standards is that there is going to be a renewed focus on being able to demonstrate compliance with your legal obligations on an on-going basis. Is the rest of the world also going to be going more down the legal compliance assurance route?

 

Enhesa will be sponsoring the “Global Risk Management” Conference Track at the 2014 IOSH Conference in London on 17 & 18 June 2014.

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