Corporate Standards – One Risk assessment vs
size does not fit all
prescriptive regulation
culture
In particular, we have found that certain issues
come up often when auditing against the
implementation of corporate policies based
on UK or US standards or best-practice.
This is largely because the ideas of safety
and the necessary precautions that are
well-established parts of working culture
in the UK and US are often not fully
realised in other countries / cultures.
This can mean it can be a challenge to
achieve acceptance and ownership of the
standards that are being applied. It also
means that local regulatory requirements
can also sometimes be overlooked –
where these might be stricter, or simply
different to those imposed elsewhere.
In Europe there is a culture of risk assessment. In
fact, there are legal obligations on companies to
carry out risk assessments for all the potential risks
at a specific site. The results of the risk assessments
are then used to inform what should be done. In
the US, regulations tend to be much more specific
and they don’t have a culture of risk assessment.
American auditors that we have worked with have
been heard to comment that it can be very hard to
perform audits in Europe because the legislation is
not prescriptive and you need to look more at the
risk assessment process, so it becomes more like a
management system audit.
Management styles and Country history, size,
organisational hierarchy population
Global EHS Risk Blog
LEGAL
COMPLIANCE
AUDITING
International Challenges
In Germanic and Scandinavian countries
responsibilities for EHS tend to be with unit
managers as part of their responsibility for an area
/ unit. Sometimes there is no overarching role to
support them and verify that the organisation as a
whole complies. In these countries plant managers
can work independently of one another. This can
be problematic as an auditor as individual unit
managers have all the information relating to H&S
and whilst one unit may perform very well, another
unit may perform poorly. In any case the auditor
is required to visit all the unit managers separately
which means a greater audit effort.
This was a particular issue for us during an audit
of a site in Sweden. We conducted a wide scale
compliance audit of the same site in both 2009
and 2012 - and the compliance situation in 2012
was still exactly the same as in 2009, as no one
had control over the individual unit managers. This
style of management is apparently common in
Sweden where roles are delegated and complete
trust is given to the people that the role is
delegated to.
It perhaps goes without saying, but the
geographic, demographic and economic aspects
of a country can also have an impact on legal
compliance auditing and it is crucial to have an
awareness of these factors. For example, in larger
countries with bigger populations, more accidents
are likely to be reported, which means that those
countries can be more adverse to certain risks.
Likewise, we have noticed that the more people
in a country have access to safety information/
knowledge the greater their perception of risk
tends to be so they tend to want to be more
involved in audits. Wealthier countries also tend to
have better funded inspection and enforcement
bodies – which can have a direct impact on
safety culture. In addition, geographical and
meteorological factors might influence the topics of
most concern in a particular country. For example,
countries with a risk of earthquakes might have
more emergency management requirements.
Countries in hot climates may be focused on
worker welfare.
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