PDC 11 – Global Corporate H&S Standards – Utilizing Regulations, Consensus Standards, and Charm

What is a “Global Corporate H&S Standard”? “Global Corporate” – Applies to all corporate sites, and the corporation has sites in more than one country. “Standard” – A central “policy” level document. Not as detailed as a “program”. Applies to sites, but is not a “site-level” document. What’s required vs. how to do it.

Why have “Global Corporate H&S Standard(s)”? Why have global corporate standards of any kind?” Nike – “Sweat shop” perception affected global sales. (Apple and some others too). Bhopal – Corporations can be held accountable for safety/health outcomes globally. Other reasons?

Who has created global standards before? How did you do it? Did you have a “team”? If yes, was this an international team? – Who was on it? Were there any barriers in creating the standard(s)? What lessons did you learn? (About creating global standards?).

XYZ Global Confined Space Standard Let’s imagine that we are all on a team of safety/health professionals, working for a large global company, and tasked with putting together a XYZ Global Confined Space Standard. Our XYZ team is from different countries all over the world. What concerns do you have? What problems may occur working in such a group? Most of the working meetings will be via Skype or email. Will this be an issue? What are some interpersonal issues that may occur? How do you resolve them?

Common/Shared Values Very Important - Start the internal discussion with shared values. What are “shared values”? Does the company have shared values? Can shared values form the core of a global H&S standard? Does your company have “core values” (or similar values) that apply universally and globally?

Key Elements of a Global Corporate Standard: Purpose and Scope Answers the questions – What is this standard about? Who does it apply to? (Employees, visitors, contractors, everybody?) – Note – this can be complicated. Standard’s Goal/Intent – What are we trying to do? Vision? Local Country/Region Statement – “All applicable international, national and local legal requirements must be complied with at all times. Where there is a difference between the requirements in this standard and legal requirements, the more stringent requirement must be applied.” - or similar. Why do we need a “Local Country/Region Statement”? (Discuss)

Key Elements of a Global Corporate Standard: Definitions Definitions answers the question – “What do these terms mean?” Does the term “confined space” mean the same thing globally? Is the term “confined space” even the “right” term to use in the standard? (Examples – “Permit-required confined space” “Non-permit required confined space” “Enclosed space” “Restricted space” “Limited-access space”) Why are definitions so important? (Discuss with your team)

What is a “Confined Space” Our global confined space standard team is working on the company’s Confined Space Program. The team members are from USA, Ontario, Canada, and the UK. One of the main “sticking points” was the definition of a confined space that could be used globally. Before I show you what they came up with, let’s (in several teams) see if we can come up with a consensus definition of a confined space, then let’s test it.

What is a “Confined Space” UK definition: “Confined space” means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk. “Specified risk” means a risk of serious injury to any person at work arising from a fire or explosion; the loss of consciousness of any person at work arising from an increase in body temperature; the loss of consciousness or asphyxiation of any person at work arising from gas, fume, vapour or the lack of oxygen; the drowning of any person at work arising from an increase in the level of a liquid; or the asphyxiation of any person at work arising from a free flowing solid or the inability to reach a respirable environment due to entrapment by a free flowing solid. Ontario definition: Fully or partially enclosed space. Not both designed and constructed for continuous human occupancy. In which atmospheric hazards may occur because of its construction, location or contents, or because of work that is done in it. Do you see anything about “permit/non permit” spaces in these definitions?

What is a “Confined Space” US definition – Confined Space: "Confined space" means a space that: (1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and (2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and (3) Is not designed for continuous employee occupancy.

What is a “Confined Space” US definition Permit-Required Confined Space: "Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics: (1) Contains or has a potential to contain a hazardous atmosphere; (2) Contains a material that has the potential for engulfing an entrant; (3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or (4) Contains any other recognized serious safety or health hazard.

Confined Space Identification Is this a confined space? (pit about 12 ft deep, oily waste in bottom)

Confined Space Identification

Confined Space Identification Is this a confined space? (Steam tunnel)

Team’s Definition of a “Confined Space” Although the definition of a CONFINED SPACE varies between jurisdictions, it is generally recognized as an enclosed or partially enclosed space that all of the following conditions apply: Has limited means of entry (ability to get into) and/or exit (ability to get out of it); Is large enough for a person to fully enter and perform work; Is not intended for regular/continuous occupancy Has the potential for significant hazards to be present Spaces that do not meet all of the above requirements are not covered under this global confined space standard, but still may have risks that are covered under other standards.

Team’s Definition of “Significant Hazards” A confined space can be any vessel, tank, container, silo, hopper, pit, bund, trench, pipe, sewer, some production equipment or other similar space which, because of its enclosed nature and difficulty of access/escape, creates conditions which may result in accident/injury and require emergency action due to any of the following significant hazards: flammable or explosive atmospheres; harmful gas, fume or vapor; free flowing solid or liquid; poor ventilation, lack or excess of oxygen; e.g. asphyxiates; very high or very low temperature; risk of engulfment, entanglement or entrapment; risk of serious injury from contact with moving parts; risk of contact with hazardous energy; Any other significant hazard not listed here.

Elements of a Global Corporate Standard: Addressing Regulatory Conflicts Not always will your definitions or implementation requirements address all of a country’s regulatory requirements and “nuance” (e.g., OSHA’s interpretations on confined spaces). How do you make it work (discuss).

Other Elements of a Global Corporate Standard: Responsibilities/Accountabilities What else?

Elements of a Global Corporate Standard: Implementation What are we implementing? (the Standard) What specifically do we want our people to do? List the general elements of implementation for a confined space standard that should be described in a Global Corporate Standard. (Hint – most all of these are ‘program’ items, for example – confined space inventory)

Wrap Up: Summary – When developing GCHSS: Questions? Have the right people involved, including leaders, both country/site SMEs and people that are motivated towards consensus. Be egalitarian – share the power, give everyone’s ideas the same level of scrutiny. Re-ground regularly on values – “Why are we doing this?” Be creative and inclusive in developing definitions. Adopt a “Local Country/Region” statement in all standards. Utilize consensus standards when appropriate. Questions?