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Are you aware of which substances are classified as endocrine disrupting chemi-cals (EDC)? Do you carry out any opera-tions involving EDC?
These are the types of questions that are being considered by many companies in light of significant consumer, government and in-
dustry concern for EDC. In order to further delve into this topic, several companies and organizations attended an Enhesa webinar on EDC on the 27 January or 2 February 2010. What this webinar addressed was that regard-
(Continued on page 20)
Responding to requests from its multinational clients, Enhesa has expanded its global regu-latory monitoring services to include a GHS (Globally Harmonized System for Classification of Labelling of Chemicals) focused offering.
GHS was conceived to create one system for categorising and labelling chemicals – glob-ally. As countries actively begin to adopt and implement GHS, the reality is very different. Each country has included its own variations, deadlines and specific requirements. It is criti-cal that companies understand these individual deviations or face dire consequences including having their products forbidden from the mar-ket.
The task is overwhelming for most multina-tionals. Thierry Dumortier, Enhesa Managing Director, says “So many of our clients are struggling to navigate what has become a maze and spending huge amounts of money and resources to try and keep up with GHS variations, we knew we had to create a cost-effective solution.”
In the United States, to cite but one example,
the Occupational Safety and Health Admini-stration (OSHA) is holding hearings in March and April regarding sweeping changes it has proposed to its Hazard Communication Stan-dard to incorporate a version of GHS. These changes will revamp information, communica-tion, and training requirements impacting over 40 million workers at 5 millions workplaces. While reclassifying all hazardous chemicals to comply with the new requirements, companies in the U.S. will have to be aware that OSHA is not proposing to adopt three of the GHS haz-ard categories. In addition to other variations OSHA is also proposing to add a requirement for text describing health effects warnings on certain pictograms.
Enhesa’s service will keep companies up-dated monthly on such GHS issues as excep-tions, differences, and deadlines in over 75 countries. The service will include on-line re-sources, conference calls, and access to regu-latory and chemical experts.
F o r m o r e i n f o r m a t i o n , c o n t a c t [email protected].
Notwithstanding dire warnings, few businesses and investors are paying much attention to the ad-verse financial consequences associated with water scarcity issues. Regulatory and policy issues are increasingly becoming strong drivers of corporate water programs. Corporate water management is emerging as a critical issue for operations, compliance, stakeholder relations, and products.
Join Enhesa for a no-charge webi-nar exploring regulations around the globe related to water scarcity issues and their impact on corpo-rations’ operations and markets. 25 March 2010 at 9:00am US EST / 2pm Central European Time
30 March 2010 at 11:00 AM EST / 4pm Central European Time
To request information about this webinar, contact Maria Panteris at [email protected].
The Enhesa Flash is distributed free of charge by Enhesa. Visit www.enhesa.com for more information about Enhesa’s regulatory compliance services.
Regulating endocrine disrupting chemicals A success story?
This edition: Focus on EHS trends in Latin America
Enhesa flash
No. 52 Mar 2010
global ehs compliance assurance
Brussels Washington
Addressing the latest EHS regulatory develop-ments worldwide
also in French
The Enhesa Flash alerts you to new EHS regulatory devel-opments in over 130 countries and jurisdictions around the globe. If you would like additional information on any of these developments or Enhesa ser-vices in general, please con-tact us at [email protected].
International water use policies, regulatory issues & trends Are you ready for water scarcity?
Regulating endocrine disrupt-ing chemicals
1, 20-23
Enhesa launches GHS tracking service
1
International water use webinar
1
Enhesa creates Global Audit Partnership
7
Enhesa and CHWMEG team-ing up again in 2010
9
Sensitive environments: oil & gas production activities
11
IOSH 2010 16
SEC issues guidance 24-25 Sustainable construction in Colombia
26-27
Forecast: Brazil’s National Climate Change Plan
28
Enhesa webinar program 31 Upcoming Enhesa events and presentations
32
Adopted EHS Regulations
Asia Pacific 2-3, 6
Africa and the Middle East 7
European Union 9
International 8
Central and Eastern Europe 10, 12-
13
Western Europe 14, 16-
18
North America 18-19,
23
Central & South America 29-30
Japan’s new era of chemical management
4-5
Enhesa launches GHS Tracking Service
Australia Audit amendments to National Green-
house and Energy Reporting Regulations Regulations adopted 14-Dec-2009 [33188]
NSW: Environmental Planning and As-sessment Amendment (Asbestos) Regu-lation 2009 published 18-Dec-2009 [32982]
NSW: New training requirements for li-censing dangerous goods drivers adopted 01-Jan-2010 [33271]
NSW: Occupational Health and Safety Amendment (Certificates of Compe-tency) Regulation 2010 published 15-Jan-2010 [33238]
NSW: Protection of the Environment Op-erations (Waste) Amendment Regulation 2009 published 18-Dec-2009 [32983]
QLD: Update on transitional arrange-ments for the Water Supply (Safety and Reliability) Act 2008 01-Dec-2009 [26372]
SA: Code of Practice on Working Hours approved 26-Nov-2009 [29803]
VICTORIA: New electricity safety regula-tions made 08-Dec-2009 [32698]
VICTORIA: New energy efficiency re-quirements for televisions, liquid-chilling packages, air conditioners and lighting products adopted 15-Dec-2009 [33298]
VICTORIA: Public Health and Wellbeing Act 2008 and Regulations 2009 came into effect: requirements on cooling tower systems 15-Dec-2009 [33299]
WA: Mines Safety and Inspection Amendment Act 2009 enters into force 03-Dec-2009 [32810]
WA: New Asbestos Licensing Laws 01-Dec-2009 [32808]
WA: Occupational Safety and Health Legislation Amendment Act 2009 enters into force 03-Dec-2009 [32811]
China 2009 Update List of Air Environmental
Protection Standards 09-Dec-2009 [27936]
3 national occupational health standards adopted 22-Jan-2010 [33426]
Amendments to the Renewable Energy Law published 26-Dec-2009 [32818]
Approved National Standards containing technical criteria with impact on EHS - December 2009 01-Dec-2009 [29685]
BEIJING: Water Resource Fee and wastewater treatment fee increased 17-Nov-2009 [32831]
Certificate on Import and Export of Toxic Chemicals and format of application documents modified 07-Jan-2010 [33432]
List of Key State-monitored Pollution Sources in 2010 published 30-Dec-2009 [29245]
List of Severely Restricted Toxic Chemi-cals for Export and Import updated 31-Dec-2009 [28276]
Measures on environmental administra-tive punishment published 19-Jan-2010 [33430]
More forklifts considered as special equipment 14-Jan-2010 [33427]
More ozone depleting substances subject to import and export control 29-Dec-2009 [33435]
New chemicals substances registration amended 19-Jan-2010 [30144]
SHANGHAI: Management Measures of Hydrants published 09-Dec-2009 [32833]
SHANGHAI: Regulation of drinking water sources protection published 21-Jan-2010 [33310]
SHANGHAI: Regulation on radioactive pollution prevention and control pub-lished 09-Dec-2009 [32832]
(continued on page 3)
Asia Pacific
2 Enhesa Brussels Washington
For more details on any of these developments, you can subscribe to the Enhesa Update (7,000 EUR/year for a corporate subscription) or register to receive detailed Monitoring Reports. For further information visit http://w w w . e n h e s a . c o m /service/monitoring.aspx or send us an email at [email protected]. We are constantly ex-panding the geographic scope of our EHS Regulatory Monitoring. The current number of countries and jurisdic-tions covered on a daily, in-depth basis now stands at over 130.
Enhesa Flash 52 - Mar 2010 © Enhesa 2010
During December 2009 and January 2010 several new environmental, health and safety regulations were adopted that could directly impact your business. The following overview provides you with a descriptive title for the regulatory developments per country, the formal adoption date and the ID number of the monitoring report in the Enhesa Knowledgebase.
Check out the Enhesa Blog for frequent updates on EHS news, information about Enhesa’s services, and more at
enhesa.wordpress.com
3 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Technical specifications of pollution con-trol for processing waste electrical and electronic equipment (HJ 527 - 2010) published 04-Jan-2010 [33433]
Tort Law adopted reinforcing strict envi-ronmental pollution liability 29-Dec-2009 [33425]
Trial management regulation on environ-mental supervision, inspection and ac-ceptance of construction projects pub-lished 17-Dec-2009 [32820]
Zhejiang: List of qualified hazardous waste operators published 28-Dec-2009 [32911]
Hong Kong Energy labels requirements for washing
machines and dehumidifiers adopted 11-Jan-2010 [32086]
More products containing ozone deplet-ing substances will be subject to import
ban 04-Dec-2009 [32681]
India The Ministry of Environment and Forests
issues the Noise Pollution (Control and Regulation) Rules 2010 11-Jan-2010 [2940]
Indonesia Procedure to obtain recommendation to
import non-hazardous and non-toxic re-usable waste published 02-Nov-2009 [33534]
Regulation on compulsory labeling for certain products is regulated 21-Dec-2009 [32891]
Regulation regarding hazardous and special goods transport on trains and railways adopted 11-Dec-2009 [33411]
(continued on page 6)
Asia Pacific
- Argentina - Argentina - Buenos Aires - Australia - Commonwealth - Australia - New South Wales - Azerbaijan - Canada - Federal - Canada - Ontario
- Canada - Saskatchewan - China - Guandong - European Union - Ghana - Gibraltar - Greece - India
- India - Maharashtra - Peru - Qatar - South Korea - Switzerland - Switzerland - Zurich
Over 130 EHS Country Profiles available Enhesa’s range of EHS Country Profiles keeps growing. We now have Country Profiles for more than 130 countries and jurisdictions. We recently developed or updated the following EHS Country Profiles:
We are now developing or updating the following Profiles:
- Belgium - Federal - Belgium - Brussels
- Belgium - Flanders - Belgium - Wallonia - Brazil
- Mexico - Turkey - United Kingdom - England
To find out about purchasing any of these or having an EHS Country Profile tailored to your specific operations, please contact us at [email protected].
2010 and 2011 will be challenging years for companies manufacturing, importing or han-dling chemical substances in Japan. Major amendments 20 May 2009 to the “Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc” (or Chemical Substances Control Law), some-times referred to as Japanese REACH, will soon come into effect in two phases: 1 April 2010 and 1 April 2011. While the Chemical Substances Control Law aims to prevent chemical substances from adversely affect-ing human health, flora and fauna. However the amendments correspond with the in-creased attention and concern of chemical safety and enhance its consistency with the global chemical control aids: WSSD (World Summit on Sustainable Development), Stockholm Convention on POPs (Persistent Organic Pollutants), and chemical regula-tions in other parts of the world such as EU REACH and US TSCA.
Phase I Japanese REACH
So what are the major impacts to chemical operations? The amended law shifts the Japanese chemical control system from hazard-based to risk-based. In Phase 1 im-plementation, the use of the restricted chemicals with long-term toxicity will be ac-cepted for essential use under stringent con-trol, and new polymers with low concern can be exempted from the notification require-ments. At the same time, non-persistent (biodegradable) chemicals will also become subject to control, while the regulatory target of the present Law has been limited to the
chemical substances that are persistent in the environment. Chemical control will also be expanded through the supply chain – handlers of chemical substances or products containing them will be responsible for haz-ard communication (incl. labelling, reporting of hazard information and new findings on hazards) and be required to comply with the technical handling guidelines.
Phase II Japanese REACH
In Phase 2 implementation, the new chemi-cal classification will be introduced, prioritiz-ing chemical substances for prompt hazard assessments. Manufacturers and importers of chemical substances with high priority for hazard assessments will have to notify the detailed use of the substances, label them, and report to the competent ministries on obtained hazard information. Another large impact to manufacturers and importers at this stage is the mandatory annual reporting on ANY chemical substances manufactured or imported into Japan in amounts of one ton or more. While the present law mainly aims to evaluate hazardous properties of new chemical substances, the amendments introduce greater control over existing chemicals that have not been regulated in Japan. These changes would require com-panies to evaluate and re-structure their chemical inventory management and com-munication processes through the supply chain.
(continued on page 5)
Japan’s new era of chemical management Coming up this April
4 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Country Profiles Narrative description and analysis of how EHS issues are
regulated.
Regulatory Registers Access to site-specific legislative requirements.
Monitoring Reports Changes to EHS regulations relevant to your company.
Permitting, Helpline and Consulting Services
Custom-made support to help obtain permits, establish EHS systems and answer all EHS questions.
Audit Protocols & ScoreCards Tools to measure compliance assurance.
Find the right tools and support for your compliance needs worldwide
5 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Japan’s new era of chemical management Coming up this April
Comparison with EU REACH
Although the amended Chemical Sub-stances Control Law is often called Japa-nese REACH, there are some differences between the law and EU REACH due to the different backgrounds from which the schemes and principles came. The Chemi-cal Substances Control Law was initially created in the 1970s to regulate PCBs, which caused a major health hazard. It has been expanded to include more chemicals with similar properties to PCBs (i.e. persis-tent, bioaccumulative, and long-term toxicity for humans, higher mammals or flora and fauna). Although non-persistent chemical substances are controlled this time with amendments, the classification of chemical substances is designed based on those properties in the amended Law and it may not necessarily correspond to SVHC (Substances of Very High Concern) under EU REACH. The regulatory scope of the amended Law is limited to substances, mix-tures and intermediates, excluding products unless they are specified. The significant role of chemical risk assessments and specifications of hazard communication re-mains for the Japanese government to de-cide, and not the industry. The pertinent ministries are: Ministry of Economy, Trade and Industry, Ministry of Health, Labour and Welfare, and Ministry of the Environment.
Nevertheless, the competent ministries have been issuing many ordinances or pub-lic notices to shape the new chemical con-trol structure in recent months; in December 2009 alone, a series of amendments was adopted with respect to specifications of hazard communication, criteria for polymers with low concern, and streamlined notifica-tion processes. Foreseeing the full imple-mentation of the new chemical management system in April 2011, a number of regulatory updates are expected throughout 2010. There will be lot of changes that companies must keep up with not only to ensure their compliance status but also to avoid loss of any business opportunities in Japan.
Are you ready for the change? Enhesa can help you keep up with the regulatory up-dates and prepare for the upcoming changes with the monthly Monitoring Re-ports, Compliance Calendars including a series of compliance deadlines and consul-tation. If you have any questions about how Enhesa can help your company meet the challenges of Japanese REACH compli-a n c e , p l e a s e c o n t a c t u s a t [email protected].
Yuko Dvorak-Miyata EHS consultant & Country Manager for Ja-pan
EnhesaではEnhesa Flashの日本語版の発行
を検討しております。 ご関心のある方はこちらの宛先までご連絡く
ださい： [email protected]
Enhesa is considering launching the Enhesa Flash in Japanese. Would this be of interest to you or any of
your colleagues? Please let us know by emailing us at: [email protected]
6 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Asia Pacific - (continued)
Regulatory Profile and
Tracking Service Do you need to know how EHS is regulated in a country and how these regulations change? Enhesa’s Regulatory Profile and Tracking Service provides a clearly explained and summarized description of current legislation in a country as well as monthly alerts on any regulatory develop-ments. This service combines essential background knowledge with the lat-est developments in EHS law. For further information, contact Enhesa at [email protected].
Japan Japanese REACH: amended reporting
requirements of hazard information and labeling requirements for chemical sub-stances 28-Dec-2009 [33321]
Japanese REACH: series of amend-ments to the notification requirements and procedures for New Chemical Sub-stances adopted 12-Jan-2010 [33319]
Substances for mandatory reporting of workers’ exposure revised for 2010: re-port due by the end of March 2011 24-Dec-2009 [32872]
Use of gaskets containing asbestos in chemical plants is prohibited as of 1 March 2010 with transitional measure 24-Dec-2009 [32854]
Malaysia Adopted Environmental Quality (Control
of Pollution from Solid Waste Transfer Station and Landfill) Regulations 2009 10-Dec-2009 [32897]
Adopted Environmental Quality (Sewage) Regulations 2009 10-Dec-2009 [32899]
Adopted the Environmental Quality (Industrial Effluent) Regulations 2009 10-Dec-2009 [32896]
Philippines Ban on import of CFCs for servicing old
equipment enters into force 11-Dec-2009
[32871]
Singapore Adopted Maritime and Port Authority of
Singapore (Dangerous Goods, Petro-leum and Explosives) (Amendment) Regulations 2009 28-Dec-2009 [33070]
Adopted Workplace Safety and Health (Safety and Health Management System and Auditing) Regulations 2009 11-Dec-2009 [30991]
South Korea Exemption on the use of hazardous sub-
stances in articles extended 07-Jan-2010 [29510]
Green Growth Act passed in the National Assembly 29-Dec-2009 [33115]
Taiwan Biodegradable plastic containers subject
to recycling obligation 07-Dec-2009 [32254]
Import and export of Hydroxylimine HCL restricted 26-Jan-2010 [31964]
Increase on rate of air pollution control fees of VOCs from stationary pollution sources slowed 31-Dec-2009 [15239]
Measures for work environment assess-ment amended 16-Dec-2009 [33023]
Permissible Exposure Limits of Airborne Hazardous Substances in Workplace amended 26-Jan-2010 [33118]
Recycling labels required for biodegrad-able plastic containers 08-Jan-2010
(Continued from page 3)
Optimize your 2010 EHS compliance audit program. Use the Enhesa Audit Protocols.
Available for more than 130 countries and jurisdictions worldwide. Updated in 2010 with the latest regulatory developments. In an Excel ScoreCard or a data feed for any audit platform. New functionalities that make auditing more efficient. Back-office support as needed to ensure success. Also available in local language.
The best value for the money from the market leader in global EHS compliance.
For more information visit us at http://www.enhesa.com/en/service/audit_protocol.aspx
7 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Enhesa creates Global Audit Partnership Bringing multinationals together to enhance EHS audit programs
In response to the needs of its clients to maximize the value of their audit programs, while minimizing the costs from a monetary and resource perspective, Enhesa created the Global Audit Partnership. In a recent survey conducted by Enhesa of 83 compa-nies, over 75% said current economic condi-tions have resulted in decreased budgets for auditing. At the same time, 91% said that the value of auditing for their companies is actually increasing. The Global Audit Part-nership not only allows companies to help drive the direction of Enhesa’s verification services but also provides a forum for shar-ing best practices, practical problem solving, and ideas for improvements regarding inter-
national audit programs. Charter members include Eaton Corporation, Barclays and General Electric. The Global Audit Partner-ship does not cost anything and member-ship will be considered for companies who purchase their Audit Protocols and Score-Cards from Enhesa. Members receive pref-erential pricing, participation in executive and auditor forums, and a seat on the En-hesa steering committee for new product development. For more information on the Global Audit Partnership Program please contact Enhesa at [email protected] or visit www.enhesa.com.
Africa and the Middle East
Egypt Decree on Standard Forms for Building
Permits Applications Issued 05-Dec-2009 [32958]
Morocco Decree on Standards for Air Quality
Issued 21-Jan-2010 [33429]
South Africa General authorisation published under
the National Water Act 18-Dec-2009 [30120]
National ambient air quality standards adopted under the Air Quality Act, 2004 18-Dec-2009 [29400]
Two existing general authorisations un-der the National Water Act replaced 18-Dec-2009 [30126]
8 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
European Union
This Enhesa Flash highlights some of the regulatory EHS developments that occurred in December 2009 and January 2010. For more details, you can consult the Enhesa Update, which provides a one-paragraph abstract for each development.
Amendments to Annex I to Regulation EC/689/2008 concerning the Export and Import of Dangerous Chemicals adopted 07-Jan-2010 [33218]
Ban on dimethylfumarate (DMF) in im-ported consumer products prolonged 28-Jan-2010 [28492]
Commission Communication on harmo-nised standards for lifts issued 05-Nov-2009 [33057]
Commission Communication on harmo-nised standards for pressure equipment issued 18-Dec-2009 [1268]
Commission publishes Decision on sec-tors to be allocated emission trading allowances for free in the third trading period 05-Jan-2010 [30096]
Decision adopting import decisions for certain chemicals under Regulation EC/689/2008 adopted 22-Dec-2009 [33208]
Directive 2009/142/EC relating to appli-ances burning gaseous fuels adopted 30-Nov-2009 [32774]
Directive establishing the third list of in-dicative occupational exposure limit val-ues adopted 17-Dec-2009 [28483]
Directive on the protection of workers from the risks related to exposure to as-bestos at work (codified version) adopted
30-Nov-2009 [28834] ECHA's second enforcement project will
focus on formulators of mixtures 10-Dec-2009 [33027]
Harmonised standards for construction products published 18-Dec-2009 [11459]
New ecolabel criteria for floor coverings published 17-Dec-2009 [32767]
Regulation concerning statistics on plant protection products adopted 09-Nov-2009 [28888]
Regulation on cosmetic products adopted 22-Dec-2009 [13951]
Regulation on the labelling of tyres with respect to fuel efficiency adopted 22-Dec-2009 [33061]
Reviewed regulation on voluntary partici-pation by organisations in EMAS adopted 25-Nov-2009 [26769]
Revised guidelines on the management of the Community Rapid Information Sys-tem (RAPEX) and of the notification pro-cedure adopted 26-Dec-2009 [32277]
Revised Regulation on a Community Ecolabel scheme adopted 25-Nov-2009 [26770]
Do you want to be fully informed on changing EHS regulations? And how they impact your business?
For more detailed and focused information, the Enhesa Regulatory Monitoring Ser-vice is a perfect solution. This service summarises all regulatory EHS develop-ments (policies, laws, regulations, propos-als, etc.) of interest to your operations and/or products in the countries you specify.
For each development, a tailored business impact analysis is made for your com-pany’s operations. In most cases, a link to the full text of the regulation is provided, either on the internet or in the Enhesa Knowledgebase of more than 35,000 texts.
The report is accompanied by a compli-ance calendar, a list of legislation and links to further information. These reports are delivered through a dedicated website tailored to your needs and connected to your company’s intranet.
Contact us at [email protected] to visit our demo site and to learn
more about any of our services.
Do your products contain batteries? March 2010 - Enhesa will release a new version of the Batteries Report shortly. The latest version includes an update of the UK and the addition of the following EU countries: - France - Italy - Luxembourg - Sweden The new reports also adds a comparison with non EU countries – Norway and Switzerland. Taking the total number of countries covered to 15. EEE subscribers will receive it as part of their subscription.
9 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Enhesa and CHWMEG teaming up again in 2010
On 13 April 2010, CHWMEG will host a Latin America Global Focus Seminar to be held in conjunction with their 2010 Annual Meeting. Enhesa experts, Eduardo Molina and Daniel Sotelino, will deliver a spotlight presentation highlighting waste and waste management issues in Latin America. En-hesa was asked to participate again this year after CHWMEG received such positive feedback on Enhesa’s 2009 participation. In other CHWMEG news, Ellen Zhang, a
frequent contributor to CHWMEG global focus seminars, provided an update on the current and evolving landscape for “polluter pays” and “producer liability” in China on a
Global Interest Committee conference call on 3 February 2010. Participants had the opportunity to pose questions and share experiences in the region. CHWMEG is a non-profit organization com-
prised of industrial companies interested in efficiently managing the waste management aspects of their environmental stewardship programs. For further info on CHWMEG, consult
www.chwmeg.org. Copies of any of the presentations mentioned above are avail-a b l e u p o n e m a i l r e q u e s t t o [email protected].
International 21st Meeting of the Parties to the Mont-
real Protocol discussed the Upgrading of the Ozone Layer Treaty 29-Nov-2009 [32726]
IATA amends dangerous goods regula-tion for Airway Bill requirement for bio-logical substances and issues guidance for lithium batteries 01-Jan-2010 [33105]
IMO introduces new marine pollutant
mark and editorial corrections to the IMDG Code in Amendment 34-08 01-Dec-2009 [33117]
UN Secretariat finalizes corrections to the European Agreement Concerning the International Carriage of Dangerous Goods by Road 25-Jan-2010 [33379]
The first Partner Forum of the Global Audit Partnership got off to a flying start on 4 March 2010. During the hour-and-a-half web conference, members discussed their audit programs, challenges faced, and shared success stories. Open, peer-to-peer
discussion and great input from all members present made it a real success. For more information on this membership group, con-tact Vicki Bain at [email protected].
Peer discussion and shared solutions kick off the Global Audit Partnership’s first Partner Forum
10 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Austria Act on environmental information
amended 30-Dec-2009 [32848] Act on Explosives adopted 04-Dec-2009
[32849] Legislation on pyrotechnic articles
adopted 30-Dec-2009 [32850] Ordinance on Ecological Electricity 2010
adopted 01-Dec-2009 [32852] Ordinance on Work Equipment amended
19-Jan-2010 [33266]
Bulgaria Law on Protection of Environment
amended 16-Dec-2009 [33059] Law on Renewables, Alternative Energy
Sources and Biofuels amended 11-Dec-2009 [33101]
Ordinance No. 7 of 2004 on Heat Preser-vation and Energy Saving in Buildings amended 08-Jan-2010 [33504]
Ordinance of Energy Efficiency corrected 20-Nov-2009 [32622]
Ordinance on Aerosol Dispensers amended 30-Nov-2009 [33502]
Ordinance on Energy Efficiency Audit, Certification of Buildings and Categories of Certificates adopted 10-Dec-2009 [33136]
Ordinance on Indicators for Energy Effi-ciency and Energy Performance of Build-ings adopted 29-Dec-2009 [33100]
Ordinance on Phytosanitary Control amended 11-Dec-2009 [33501]
Ordinance on Terms and Conditions for Periodical Training and Instruction of Workers and Employees under Health and Safety Rules slightly amended 15-Jan-2010 [33507]
Ordinance on the Essential Require-ments in Respect of Measuring Devices amended 03-Dec-2009 [33503]
Ordinance on the Terms and Conditions for Periodical Training and Instruction of Workers and Employees under Health and Safety Rules adopted 16-Dec-2009 [33156]
Organizational Regulations of the Fi-nance Ministry amended 15-Dec-2009 [33132]
Organizational Regulations of the Health Ministry amended 03-Dec-2009 [33133]
Organizational Regulations of the State Construction Supervision Directorate adopted 20-Jan-2010 [33505]
Regulations of Ministry of Labour and Social Policy adopted 10-Nov-2009 [32624]
Regulations of the Council of Ministers and its Administration issued 17-Dec-2009 [32615]
Croatia Act on Technical Requirements for Prod-
ucts and Conformity Assessment adopted 29-Jan-2010 [33533]
Act on Water Management Financing adopted 19-Nov-2009 [32627]
Act on Waters adopted 11-Dec-2009 [32626]
New Labor Act adopted 04-Dec-2009 [32220]
Regulation on Amendments and Supple-ments to the Regulation on Risk Assess-ment issued 23-Nov-2009 [33037]
Regulation on Management of Packaging and Packaging Waste amended 21-Dec-2009 [33523]
Regulation on Management of Waste Tires amended 21-Dec-2009 [33515]
Regulation on the Management of Waste Batteries and Accumulators amended 21-Dec-2009 [33529]
Regulation on the Management of Waste Electrical and Electronic Devices and Equipment (WEEE) amended 21-Dec-2009 [33527]
Regulation on the Management of Waste End-of-Life Vehicles amended 21-Dec-2009 [33524]
Regulation on Waste Oil Management amended 21-Dec-2009 [33530]
Czech Republic Decree detailing mining waste manage-
ment plans and implementing the Act on Mining Waste Management issued 01-Dec-2009 [33127]
Decree implementing Act on the Promo-tion of Electricity from Renewable Energy Sources issued 10-Nov-2009 [33125]
Decree implementing the Act on Mining Waste Management issued 01-Dec-2009 [33126]
Decree on the measuring of emissions from stationary sources amended 12-Jan-2010 [33409]
Emission limits and other conditions re-ferring to the requirements for rubber industry and sulphur production amended 21-Dec-2009 [33028]
Government Regulation on Emission Limits and Other Operating Conditions for Stationary Combustion Sources of Air Pollution modified 21-Dec-2009 [33012]
(Continued on page 12)
Central and Eastern Europe
Enhesa — a growing team The Enhesa team con-tinues to grow, and in recent months our team has grown to more than 60 staff members from more than 30 different countries, supported by a network of more than 300 in-country experts. In late January, the En-hesa team in Washing-ton, DC welcomed some new consultants from Thailand, Korea, and China. Enhesa is continuously looking for talent to join its team of dedicated EHS regulatory consult-ants. If you are passionate about environmental and health and safety law and would like to help businesses achieve and maintain compliance, visit our website for va-cancies and send your application to: [email protected]
Sensitive environments: oil and gas production activities Enhesa’s Regulatory Registers assure protection
11 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Oil and gas exploration and production are perhaps the most closely scrutinized activi-ties of all when it comes to protecting the environment, and even more so when it comes to sensitive, or even protected envi-ronments. Indeed, a company’s very per-mission to operate will be contingent at the very least on meeting both the spirit and the letter of the law governing the protection of such environmental treasures. So how can such companies ensure that they are fully compliant with their legal obligations at all jurisdictional levels? Perhaps the most ef-fective approach is to compile a comprehen-sive and detailed registry of all environ-mental regulatory and legal requirements that the operations must comply with and link these to compliance verification tools, such as detailed EHS compliance audit pro-tocols. But how can a company ensure that all such requirements are properly identified and included in such registries and proto-cols?
Enhesa was engaged by one of the world’s six “supermajor” oil companies to develop just such a registry for three separate activi-ties: two in central Asia and one in the In-dian Ocean off the coast of Australia. En-hesa’s client, an American multinational energy company active in more than 180 countries and engaged in every aspect of the oil and gas industry, from exploration to production to refining to marketing and transportation, tasked its global business units to develop the necessary mechanisms to ensure that all activities and operations are conducted in strict compliance with all applicable EHS laws and regulations. Three of these business units turned to Enhesa to develop the necessary details of regulatory requirements with which they must comply.
Two such business units are engaged in producing and transporting oil and gas, as well as manufacturing pipeline components, in central Asia and are taking positive steps to ensure that all operations under their con-trol are carried out in full compliance with best management practices as well as all applicable environmental laws and regula-tions. Enhesa has been tasked to identify the requirements and to detail the com-pany’s obligations in Regulatory Registers for Kazakhstan, Azerbaijan, Turkey and Russia that management can use to imple-ment the necessary compliance programs
as well as to meet the requirements of the ISO 14001 international standard for envi-ronmental management.
Conscious of past concerns with respect to assuring full compliance, and determined to ensure that its permission to operate should not be compromised, particularly in one of the world’s oldest environmental reserves, the third business unit tasked Enhesa to detail all legal and regulatory requirements its activities must comply with for the plan-ning, construction, operation, and even eventual decommissioning of all facilities in Western Australia. Such activities and in-stallations ranged from the primary subma-rine gas collection operation, to undersea and overland gas pipelines, a liquefied natu-ral gas (LNG) plant, as well as all ancillary
and support infrastructure and activities, such as worker accommodation and recrea-tion facilities, waste management installa-tions, a deep-sea port facility, an airstrip, and marine transport activities and opera-tions.
Of particular concern was that these opera-tions are being carried out in a Class A na-ture reserve subject to some of the most stringent environmental protection require-ments administered by Australian Common-wealth and State of Western Australia au-thorities. Home to many rare and endan-gered marine species and birds, the island is subject to extensive quarantine and other protective measures with which compliance is paramount to assure continued permis-sion to operate. Enhesa’s Regulatory Reg-isters, and the data management system to which they are uploaded, have played a critical role in assuring the authorities of the seriousness with which our client takes its regulatory obligations and have thus been instrumental in helping to secure the needed permits and authorizations to proceed with the development of Western Australia’s larg-est natural gas reserve.
Paul Beatley
Director
Meghan White
Project Manager & EHS Consultant
12 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Major Accident Prevention Act amended 11-Dec-2009 [33005]
Regulation defining poisonous sub-stances and their noxious quantities for the purposes of the Penal Code adopted 14-Dec-2009 [33039]
Estonia Conditions for the establishment of
groundwater body environmental status and its categories by authorities adopted 29-Dec-2009 [33548]
Format and conditions for submitting a waste report and the scope of data to be submitted issued 15-Jan-2010 [33549]
Procedure and rates for compensating damage caused to the environment by damaging protected natural objects or mammals or birds amended 10-Dec-2009 [33104]
Regulation concerning packaging deposit and marking with a deposit information amended 16-Dec-2009 [33103]
Specifications of proceeding with docu-ments for import, export and transit of radioactive waste amended 10-Dec-2009 [33102]
Hungary Amendment of the Chemicals Act in the
light of the CLP Regulation adopted 29-Dec-2009 [31944]
Decree on data supply obligations related to greenhouse gas emissions adopted 30-Dec-2009 [27270]
Decree on the election of the Works Council adopted 30-Dec-2009 [33080]
Decree regulating marketing and use restrictions of substances and prepara-tions adapted to Annex XVII to REACH Regulation 09-Jan-2010 [33540]
Government Decree concerning the ac-tivity of the occupational health and safety expert adopted 30-Dec-2009 [32728]
National Environmental Protection Pro-gramme 2009-2014 adopted 09-Dec-2009 [29119]
Revised Decree on aerosol products published 08-Jan-2010 [33541]
Latvia Provisions for the content of ELVs, pack-
aging, disposable tableware and goods harmful to environment management agreement proposed 10-Dec-2009 [33073]
Regulation on the Management Proce-
dures for Different Types of Hazardous Waste, concerning batteries and accu-mulators, amended 26-Jan-2010 [32632]
Regulations on Registration Procedures of Producers of Batteries and Accumula-tors and on the Holder of the Registry amended 15-Dec-2009 [32633]
Regulations Regarding Investigation and Registration of Occupational Illnesses amended 19-Jan-2010 [33555]
Poland Draft Principles for Draft Amendment of
the Environmental Protection Act to im-plement CAFE Directive proposed 28-Jan-2010 [33485]
Ordinance on product fee for batteries and accumulators issued 18-Dec-2009 [30908]
Ordinance on the annual collection tar-gets for waste portable batteries and accumulators issued 03-Dec-2009 [30907]
Ordinance on the format for reporting on kind, mass of treated waste batteries and accumulators and recycling efficiency levels issued 22-Dec-2009 [31633]
Romania Decision on safe operation of pressure
vessels, lifting and fuel related equip-ment adopted 25-Nov-2009 [33162]
Measures to implement ecodesign of energy using products established 25-Nov-2009 [33161]
Order concerning certification of electri-cians issued 19-Nov-2009 [33159]
Order on updating fees and taxes calcu-lation methodology for plastic shopping bags approved 02-Dec-2009 [33158]
WEEE regulation and regulation on re-stricted use of dangerous substances in EEE amended 02-Dec-2009 [33163]
Russia Adopted Amendments to the Administra-
tive Offences Code 28-Dec-2009 [33573] Adopted decree on safety of personal
protective equipment 24-Dec-2009 [33535]
Adopted list of products subject to com-pulsory certification and a list of products subject to conformity declaration 01-Dec-2009 [33150]
Adopted Technical Regulation on the Safety of Buildings and Structures 30-Dec-2009 [33547]
Amended Law on Compulsory Occupa-
(Continued from page 10)
(Continued on page 13)
Central and Eastern Europe (continued)
EHS Regulatory Registers Regulatory Registers are an essential tool for EHS compliance and, espe-cially, for assessing against ISO 14001 and OHSAS 18001. By allow-ing companies to identify and maintain an up-to-date list of EHS legisla-tion that is applicable to their particular opera-tions, the tool provides a solid basis for a compli-ance program.
This service is available from Enhesa for facilities in more than 50 countries and jurisdictions. The latest updates include Kazakhstan in dual lan-guage. New Regulatory Registers are being de-veloped for Luxem-bourg, Russia, Turkey and Azerbaijan. The Regulatory Registers for the United Kingdom, Belgium, the Nether-lands and France are currently being updated. Contact us for further i n f o r m a t i o n a t [email protected].
13 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
tional Insurance 28-Nov-2009 [33151]
Slovakia Decree amending Decree on legal meas-
uring units issued 11-Dec-2009 [33252] Decree implementing some provisions of
Act No. 309/2009 on Support of Renew-able Energy Sources and Combined Heat and Power (co-generation) issued 10-Dec-2009 [33265]
Decree No. 587/2009 Coll. setting out the contents and procedure of certification for energy auditors issued 10-Dec-2009 [33255]
Decree on labeled consumer packaging amended 11-Dec-2009 [33236]
List of labeled construction products adopted 27-Nov-2009 [33090]
Slovenia Decree on Limit Values for Environment
Noise Indicators amended 24-Dec-2009 [33560]
Decree on the Storage of Hazardous Liquids in Fixed Storage Facilities issued 10-Dec-2009 [33091]
Spatial Planning Act amended 15-Dec-2009 [33561]
Turkey Amendment to Notification on import of
certain explosives 2010/11 published 31-Dec-2009 [13661]
Amendment to the Notification on Import of PPE 2010/11 published 30-Jan-2010 [13724]
Amendment to the Regulation on Envi-ronmental Impact Assessment published to include certain exploration activities 19-Dec-2009 [26792]
Amendment to the Tariff and Directive on Mandatory Liability Insurance of Hazard-ous Substances published 08-Jan-2010 [10639]
Implementation Notification of the Regu-lation on Workplace Health and Safety Units and Common Health and Safety Units published 09-Dec-2009 [32736]
New Regulation on Operation Certificate enters into force 04-Dec-2009 [32737]
Notification on control of metal scrap due to Environmental Protection 2010/23 published 31-Dec-2009 [16648]
Notification on Controlled Waste 2010/3 published 31-Dec-2009 [8037]
Notification on Import of Batteries and Accumulators 2010/15 published 31-
Dec-2009 [11839] Notification on Import of Chemical Sub-
stances Attached to the Chemical Weap-ons Agreement 2010/17 published 31-Dec-2009 [8067]
Notification on import of Ozone Depleting Substances 2010/14 published 31-Dec-2009 [8046]
Notification on import of radioactive sub-stances and apparatus which are used for radioactive substances 2010/3 pub-lished 31-Dec-2009 [8076]
Notification on import of some products which must bear CE mark 2010/9 pub-lished 31-Dec-2009 [16180]
Notification on Import of Substances Af-fecting Health and Safety at Work 2010/13 published 31-Dec-2009 [8071]
Notification on Safety Information Forms is repealed, because Regulation on Safety Information Forms was published to comply with the REACH Regulation 23-Dec-2009 [28209]
Notification on Standardization of Foreign Trade on Import of Products Controlled by the Ministry of Health 2010/4 pub-lished 31-Dec-2009 [14204]
Notification on the Administrative Fines 2010/1 imposed in accordance with the Environmental Law issued to increase fines 07-Jan-2010 [13791]
Notification on the Control of Chemicals due to Environmental Protection 2010/6 published 31-Dec-2009 [10691]
Notification on the control of fuel due to environmental protection 2010/7 pub-lished 31-Dec-2009 [10015]
Notification on the registration of user certificates obtained for dual use goods and technologies 2010/12 published 31-Dec-2009 [13774]
Regulation on Biocidal Products (98/8/EC) enters into force 31-Dec-2009 [32815]
Regulation on Measuring Instruments and Methods of Metrological Control (2009/34/EC) enters into force 11-Jan-2010 [32708]
Ukraine Adopted List of Products and Substances
Import and Export of Which is Subject to Licencing 23-Dec-2009 [33138]
Ukraine accedes to Agreement on the Carriage of Dangerous Goods by Inland Waterways 17-Nov-2009 [33575]
(Continued from page 12)
Central and Eastern Europe (continued)
14 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Western Europe
Belgium Federal: Act concerning a general rule for
closed smoking areas available to the public and to protect workers from to-bacco smoke adopted 22-Dec-2009 [32859]
Federal: List containing deviations from ADR and RID 2009 published 29-Jan-2010 [32879]
Federal: New ADR signs for tunnels en-tered into force 01-Jan-2010 [33034]
Federal: Programme Act adopted 23-Dec-2009 [33036]
Federal: Prohibition and recall of certain electrical appliances 07-Dec-2009 [33053]
Federal: Recall of certain gas appliances 04-Dec-2009 [33033]
Federal: Royal Order determining the amounts, payment procedure and fees concerning ionizing radiation rules adopted 05-Jan-2010 [32377]
Federal: The voluntary use of additional measurement unit labelling prolonged 03-Dec-2009 [33032]
Brussels Capital-Region: Decision imple-menting Directive 2006/66/EC on batter-ies and accumulators and waste batter-ies and accumulators 10-Dec-2009 [32780]
Brussels Capital-Region: Intervention and remediation limit standards for soil contamination adopted 17-Dec-2009 [33145]
Flemish Region: Adopted implementing Decision concerning subsidies for eco-logical investments 19-Jan-2010 [29014]
Flemish Region: Aircraft operators come under the emission trading scheme (ETS) 07-Dec-2009 [32268]
Flemish Region: Programme Decree concerning the budget for 2010 adopted 18-Dec-2009 [32403]
Flemish Region: Stricter requirements for energy efficiency of buildings entered into force 15-Dec-2009 [28100]
Wallonia: Order on the promotion of elec-tricity produced through renewable en-ergy sources and cogeneration amended 14-Jan-2010 [33511]
Wallonia: Temporary provisions on en-ergy efficiency of buildings adopted 17-Dec-2009 [33512]
Denmark New rules on flammable liquids entered
into force 04-Jan-2010 [31863]
Finland Adopted a Decree on the substances
listed in Annex VI of the CLP Regulation 11-Jan-2010 [33233]
Adopted a Decree to restructure the envi-ronmental permitting regime 29-Dec-2009 [33212]
Adopted an Act on the Finnish Environ-ment Institute 11-Dec-2009 [32747]
Adopted Decree amending the Decree on aerosols 17-Dec-2009 [32770]
Environmental and occupational health and safety administrations reorganised 30-Nov-2009 [33183]
France 2010 Finance Law adopted 31-Dec-2009
[32041] 2010 Finance Law for Social Security
adopted 27-Dec-2009 [32166] Amending Finance Law for 2009 adopted
31-Dec-2009 [32593] Circular on the 2010 inspection campaign
of the Labor Inspectorate issued 23-Dec-2009 [33483]
Decision on the exemption for the peri-odic internal verification of pressure equipment containing certain gases is-sued 15-Dec-2009 [33481]
Decree amending the scope of the gen-eral tax on polluting activities for various types of classified installations adopted 16-Dec-2009 [32898]
Decree introducing the concept of sub-stantial modification of a classified instal-lation subject to authorization or declara-tion adopted 11-Dec-2009 [32892]
Decree relating to the information of workers on the risks for their health and safety adopted 21-Jan-2010 [33270]
Decree relating to the monitoring of chemical risks in workplaces adopted 15-Dec-2009 [32965]
General Water Management Plans adopted 17-Dec-2009 [32970]
New provisions on marketing of biocides adopted 30-Dec-2009 [32976]
Order amending general requirements Orders with respect to modifications of classified installations subject to declara-
(Continued on page 16)
15 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Australia - Victoria Australia - South Australia Brazil - Rio de Janeiro
Brazil - Sao Paolo Austria Belgium - Brussels Canada - British Columbia Canada - Alberta Canada - Quebec
China - Guangdong China - Jiangsu China - National China - Shenzhen City China - Shandong China - Shanghai Ghana France Germany
Netherlands New Zealand Taiwan Turkey United States - Indiana United States - Nebraska
United States - Oklahoma
United States - Tennessee
Australia - New South Wales Azerbaijan Belgium - Flanders Belgium - Wallonia Brazil - Rio de Janeiro Canada - Ontario
Canada - Saskatchewan China
Finland Gibraltar Greece Japan Kazakhstan Mexico Mexico - Tabasco Mexico - Veracruz
Peru Poland South Korea Spain Switzerland - Neuchâtel United Kingdom - England
United States - Ohio United States - Utah
We have also started developing or updating the following Protocols, which will be avail-able for purchase in the coming months.
We pride ourselves on being able to offer the most up-to-date Audit Protocols worldwide. Since the previous issue of the Enhesa Flash in January 2010, Enhesa has updated or developed the following Audit Protocols, bringing the total to over 130. These Audit Proto-cols are now available for only USD $6600 each (excluding states).
Latest Enhesa Audit Protocols
Do you have an audit in the pipeline but no audit tool as of yet?
Looking to share development costs on new protocols? We have received requests for a number of new Audit Protocols, and are looking for cus-tomers who may also need audit tools in these locations and would be interested in shar-ing the development cost for these. If you are interested in Audit Protocols for any of the following (or other) locations, please get in touch with us to discuss more favourable rates.
Bolivia Botswana Cameroon China - Zhongshan city Ecuador Fiji Gabon Georgia Guatemala Israel
Jordan Kenya Lithuania Luxembourg Mauritius Mozambique Northern Ireland Oman Panama Puerto Rico
Serbia Seychelles Slovakia Tanzania Uganda Vietnam Yemen Zambia Zimbabwe
16 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Western Europe (continued)
tion and authorization adopted 15-Dec-2009 [32045]
Order approving the ASN Decision deter-mining the conditions of practice of exter-nal radiation protection experts 24-Nov-2009 [32968]
Order determining certain thresholds above which the modification of a classi-fied installation is considered as substan-tial adopted 15-Dec-2009 [32043]
Order determining the terms of the train-ing of workers on the prevention of the risks related to asbestos adopted 22-Dec-2009 [33413]
Order establishing the 2009 fees for the administration of the accounts of green-house gas allowances holders adopted 28-Dec-2009 [33174]
Order establishing the cases into which the obligations relating to the cadmium content in portable batteries and accu-mulators do not apply adopted 18-Nov-2009 [32901]
Order further implementing CLP Regula-tion adopted 07-Dec-2009 [32964]
Order on the terrestrial transport of dan-gerous goods amended 02-Dec-2009
[32969] Order relating to the placing on the mar-
ket of biocidal active substances and biocidal products amended 23-Nov-2009 [33463]
Order relating to the procedures of regis-tration and declaration to the batteries and accumulators national register adopted 18-Nov-2009 [32902]
State aids for the promotion of clean ve-hicles reviewed 18-Dec-2009 [32973]
Germany Amended Ordinance on Small Heating
Installations (1. BImSchV) published 01-Feb-2010 [15542]
Second Ordinance on the amendment of the Ordinance concerning the Transport of Dangerous Goods by Sea (GGVSee) entered into force 30-Dec-2009 [32954]
Bln: Act on Access to Geo Data Bln pub-lished 12-Dec-2009 [32955]
Bln: Ordinance on the Construction of Service Rooms for Electrical Installations Bln (EltBauV Bln) entered into force 22-Jan-2010 [33259]
Bln: Ordinance on the enforcement of the
(Continued from page 14)
(Continued on page 17)
Enhesa will once again be exhibiting and presenting at the annual Institute of Occupa-tional Safety and Health (IOSH) Conference in Glasgow, Scotland on 24 and 25 March 2010. IOSH is a UK chartered body for health and safety professionals which has more than 35,000 members in 85 countries. It is the world’s largest professional health and safety organisation.
Enhesa will be meeting clients and pre-senting its services to IOSH delegates at stand G29 where Enhesa consultants Victo-ria Bain, Tjeerd Hendel-Blackford and Paul Beatley will be available for a chat and to walk you through our services in order to demonstrate how we can help you to achieve international EHS regulatory compli-ance.
Enhesa will also be delivering two presen-tations as part of the conference. On 24 March at 3pm, Enhesa Director and Co-Founder, Paul Beatley, will be delivering a keynote presentation to the main Confer-ence on “Complying with international health and safety requirements despite tighter budgets.” The presentation will look at the following:
Combining business interests with health and safety laws and regulations A particular focus on compliance across i n t e r n a t i o n a l o p e r a t i o n s Practical case studies of how companies are coping with more restrained budgets while facing more inspections and tougher enforcement
In addition, on 25 March at 2 pm, Enhesa Project Manager and Senior Consultant, Tjeerd Hendel-Blackford, will be delivering a presentation in the IOSH Spotlight Theatre on the “Enhesa Regulatory Forecast” – examining the international health and safety regulatory issues that are going to be of most concern to companies in the next decade and beyond.
Come and meet Enhesa at IOSH!
Enhesa will be hosting a dinner in Glasgow on the evening of 24 March, following the first day of the conference. If you would be interested in attending the dinner or have any further questions about Enhesa at IOSH 2010, please contact Tjeerd Hendel-Blackford at [email protected] or at +44 07825-889172.
Institute of Occupational Safety and Health (IOSH) 2010
Enhesa to present : EHS auditing & EHS regulatory forecast
17
Western Europe (continued)
Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Ordinance on Energy Saving Berlin (EnEV-DV Bln) entered into force 30-Dec-2009 [32838]
HH: Geo Data Infrastructure Act HH pub-lished 30-Dec-2009 [32956]
NRW: Act on the enforcement of the Re-newable Energies Heat Act NRW (EEWärmeG-DG NRW) entered into force 23-Dec-2009 [32842]
NRW: Act to abolish the Water Abstrac-tion Levy NRW entered into force 15-Dec-2009 [32003]
Italy Class action possible in Italy from 1
January 2010 01-Jan-2010 [33165] Financial responsibility for the financing
of the WEEE system postponed again 30-Dec-2009 [33148]
Integrated environmental fee system postponed again 30-Dec-2009 [29985]
Legislative Decree on VOC restrictions in paints amended 30-Dec-2009 [12382]
New guidelines for the participation to the CONAI system for the management of packaging and packaging waste 01-Nov-2010 [1617]
Renewables compulsory for new con-structions from 1 January 2010 01-Jan-2010 [33179]
System for tracing waste starts to oper-ate 13-Jan-2010 [33166]
Lithuania Law on Waste Management amended
with regards electrical and electronic equipment labelling 22-Dec-2009 [33081]
Order on fluorinated gases and ozone depleting substances recording and re-porting adopted 07-Jan-2010 [33546]
Order on greenhouse gases monitoring and reporting adopted 11-Jan-2010 [33542]
Order on providing information on chemi-cals amended 09-Dec-2009 [32743]
Luxembourg Regulation implementing an agreement
on harassment and violence at work adopted 13-Jan-2010 [33514]
Subsidies policy for the purchase of en-ergy efficient refrigerators and freezers extended 11-Dec-2009 [32865]
Netherlands Adopted amendment to Act on Environ-
mental Taxes 29-Dec-2009 [16497] Adopted amendment to Goods Act Deci-
sion on general chemical product safety 15-Dec-2009 [32750]
Adopted Amendment to Implementation Rule Energy-Investment Tax Deduction 2001 28-Dec-2009 [16441]
Adopted amendment to Rule random writing-off and investment deduction en-vironmental investments 21-Dec-2009 [28816]
Adopted amendment to Rule Transport of Dangerous Goods Over Land relating to tunnel restrictions 07-Jan-2010 [33085]
Adopted amendments to the Subsidy Rules falling under the Environmental Management Act 30-Dec-2009 [32457]
Amendment of Subsidy Rule Environ-mental Technology 23-Dec-2009 [28324]
Amendment to Rule appointing eco-design products published 19-Jan-2010 [32547]
Amendment to Rule Energy Performance of Buildings adopted 31-Dec-2009 [32953]
Decision on emission restrictions for me-dium-sized combustion installations envi-ronmental management published 21-Dec-2009 [27994]
Published Rule amending Rule allocation categories renewable energy production 2009 29-Dec-2009 [29169]
Rule adding several substances to the Rule concerning packaging and use-materials published 19-Jan-2010 [28315]
Rule allocation categories renewable energy production 2010 published 25-Jan-2010 [32748]
Rule on certified organisations for the transport of dangerous substances pub-lished 21-Dec-2009 [32769]
Subsidy Rule on Energy and Innovation published 29-Dec-2009 [32868]
Water Act and Implementing Act, Deci-sion and Rule into force are published and enter into force 18-Dec-2009 [28686]
Norway Directive 2001/81/EC on National Emis-
sion Ceilings for Certain Atmospheric Pollutants to be part of the EEA-agreement 04-Dec-2009 [33075]
New requirements concerning occupa-tional health services have been adopted 18-Dec-2009 [32740]
Portugal Entry into force of the forestry code post-
poned to 2011 23-Dec-2009 [31468]
(Continued from page 16)
(Continued on page 18)
91% of companies
say the value of
auditing is increasing.
18 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
North America
Canada Ministerial Condition No. 15713 pub-
lished regarding 1-butanol 05-Dec-2009 [32544]
Notice published with respect to sub-stances in the National Pollutant Release Inventory for 2009 05-Dec-2009 [16874]
Notice with respect to Batch 12 Chal-lenge substances published 26-Dec-2009 [33106]
Orders amending the Domestic and Non-domestic Substances List adopted 09-Dec-2009 [32534]
Significant New Activity Notice No. 15754 adopted regarding alkyl dioic acid 26-Dec-2009 [33107]
ALBERTA: Industrial Railway Regulation enters into force 14-Dec-2010 [32888]
(Continued on page 19)
Labour Code partially regulated 21-Jan-2010 [31405]
Ordinance on employer's reporting obli-gations adopted 21-Jan-2010 [33181]
Ordinance on phytosanitary measures reviewed 31-Dec-2009 [27926]
Spain Regulation on thermal installations of
buildings modified 11-Dec-2009 [33042] Resolution prohibiting the placing on the
market of any product containing di-methylfumarate (DMF) adopted 28-Jan-2010 [33338]
Sweden Regulation (SNFS 1991:4) on control of
emission of nitrogen oxide and sulfur oxides to air from combustion in fixed devices repealed 27-Dec-2009 [32844]
Switzerland New Ordinance on electromagnetic com-
patibility adopted 08-Dec-2009 [32805] Ordinances on waste shipment and on
the treatment of waste amended 08-Dec-2009 [32326]
Phase-out provisions for electrical appli-ances in non-compliance with energy efficiency requirements adopted 22-Dec-2009 [32510]
Regulatory framework on second-hand smoking to enter into force in May 2010
08-Dec-2009 [30563]
United Kingdom Climate Change Levy Solid Fuel Exemp-
tion Revoked 15-Dec-2009 [32417] First stage of the revised EU Emissions
Trading Scheme Directive on reporting transposed in UK 02-Dec-2010 [30780]
ENG, WAL: Environmental Permitting Regulations amended 20-Dec-2009 [32378]
ENG, WAL: Legislation giving the secre-tary of state powers to transpose EU Directive requirements adopted 14-Jan-2010 [30430]
ENG, WAL: The Water Resources Act 1991 amended 25-Nov-2009 [32380]
ENG: Local Authorities gain enforcement powers for Volatile Organic Compounds 02-Dec-2009 [32369]
NI: Amendment to Asbestos Regulation Adopted 14-Dec-2009 [33392]
NI: Pollution Prevention and Control Regulations Amended 04-Dec-2009 [31273]
SCO: The Water Environment (Groundwater and Priority Sub-stances)(Scotland) Regulations 2009 adopted 24-Nov-2009 [32385]
Audit Protocols and ScoreCards now available for all Canadian provinces Possible future expansion to include the Canadian Territories?
Enhesa has expanded its Canadian cover-age to include all 10 Canadian prov-inces. Additionally, program managers are considering developing tools for the Cana-dian territories (Northwest Territories, Yukon and Nunavut) depending upon client inter-est.
If you are interested in the Canadian Territo-ries, please contact Meghan White, lead Canadian consultant, [email protected] directly. For more information on all of En-hesa’s Canadian services contact either Meghan or [email protected].
Western Europe - (continued)
Enhesa Expanding US State Audit Proto-col and ScoreCard offering
In response to client de-mand, Enhesa is increasing the number of available US state Audit Protocols and Scorecards to 30 in 2010 and 50 by 2011. Victoria Bain, Head of Enhesa Audit Protocol Program com-ments, “Many of our long time Audit Protocol clients have made Enhesa Audit Protocols such an integral part of their EHS audit pro-grams, that not having the same tool for the US was becoming more than an inconvenience for them. As always we want to meet our clients’ needs; thus, we in-vested in increasing our US offering.”
Enhesa’s US State Audit Protocols and Score-cards provide the same timely, accurate and easy to use compliance tools as Enhesa’s traditional interna-tional Audit Protocols/ScoreCards. One added advantage is that the US State Audit Protocols/ScoreCards integrate fed-eral and state requirements into one easy to use tool.
For more information on availability of US State Audit Protocols and Scorecards contact Enhesa at [email protected] or call +1.202.552.1090.
State-level Audit Protocols are priced at US$3,000 per state.
19 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
North America (continued)
BRITISH COLUMBIA: Ministry of En-ergy, Mines and Petroleum Resources adopts amendments to Renewable and Low Carbon Fuel Requirements regula-tions 21-Dec-2009 [32876]
BRITISH COLUMBIA: WorkSafeBC's Board of Director amends policy for re-peat penalties 09-Dec-2009 [32883]
BRITISH COLUMBIA: Recycling Regula-tion, B.C. Reg. 449/2004, amended 11-Dec-2009 [33414]
ONTARIO: Amendments adopted to On-tario Regulation 153/04, Brownfields Records of Site Condition 16-Jan-2010 [27682]
ONTARIO: Amendments to Ontario Regulation 419/05: Air Pollution - Local Air Quality adopted regarding technical standards and acrolein 22-Dec-2009 [33108]
ONTARIO: Designated Substances Regulation adopted under the Occupa-tional Health and Safety Act 02-Jan-2010 [33454]
ONTARIO: Environmental Protection Amendment Act (Greenhouse Gas Emis-sions Trading) 2009 adopted 15-Dec-2009 [29962]
ONTARIO: Greenhouse Gas Emissions Reporting Regulation adopted 01-Dec-2009 [31315]
ONTARIO: New or revised Occupational Exposure Limits adopted for 36 hazard-ous chemicals substances 02-Jan-2010 [33147]
ONTARIO: Ontario Regulation 213/91 - Construction Projects amended 12-Dec-2009 [33110]
ONTARIO: Regulation made under the Toxics Reduction Act adopted 19-Dec-2009 [31203]
Quebec: First list of sustainable develop-ment performance indicators adopted 23-Dec-2009 [31161]
Quebec: Greenhouse gas emissions reduction target for 2020 adopted 09-Dec-2009 [31669]
Quebec: Regulation on GES emissions for vehicles issued 02-Dec-2009 [32802]
Quebec: Regulation on halocarbons amended 23-Dec-2009 [32803]
Mexico Labelling and packaging requirements for
tobacco products published 24-Dec-2009 [33051]
List of fossil fuels to identify users with high energy consumption patterns pub-lished 14-Jan-2010 [33386]
NOM-030-STPS-2009 for health and safety prevention services at workplaces adopted 22-Dec-2009 [31451]
NOM-155-SEMARNAT-2007 that estab-lishes environmental protection require-ments for gold and silver minerals leachate systems published 15-Jan-2010 [33497]
The Fourth Emission and Contaminant Transfer Register Report with information generated in 2007 is published 18-Dec-2009 [32919]
United States Adopted NESHAP for the chemical
preparations area source category 30-Dec-2009 [31270]
Adopted revision of the national ambient air quality standard for oxides of nitrogen 09-Feb-2010 [15416]
Adopted revisions to TSCA regulations to facilitate electronic reporting 06-Jan-2010 [28227]
Adopted rule regarding phytosanitary treatment of wood packaging 26-Jan-2010 [33418]
Ban on the sale or distribution of certain pre-charged appliances published 01-Jan-2010 [32824]
Certification, compliance, and enforce-ment requirements adopted for con-sumer products and certain commercial and industrial equipment 05-Jan-2010 [33184]
Consumer Products and Safety Commis-sion issues exemptions to lead limits for component parts in children's products 20-Jan-2010 [29034]
EPA published final revisions to OECD hazardous waste imports and exports rule, under RCRA 08-Jan-2010 [27405]
Expiration date of 2008 general stormwa-ter permit for construction activities ex-tended by one year 28-Jan-2010 [32128]
Final rule limiting the polymer exemption to premanufacture notice requirement 27-Jan-2010 [11837]
Hazardous materials transport penalties increased 29-Dec-2009 [33002]
Mandatory product recall rule adopted 21-Jan-2010 [29230]
Notice issued regarding applications for
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20 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
less of the controversial nature of the scien-tific research, countries are still proposing and adopting measures that regulate how certain priority EDC are used. The focus was on Canada, which is especially relevant because it has been particularly systematic and comprehensive in promoting measures to regulate the use of key EDC. However, for the purposes of comparison, a consid-eration of how the US and the EU are deal-ing with these substances was also dis-cussed. North American and the European Union have taken the upper hand globally in attempting to classify, assess and regulate potentially harmful EDC.
The Organisation for Economic Co-operation and Development (OECD) it has adopted the following working definition for an EDC and a potential EDC as agreed upon by an OECD Workshop hosted by the European Union and World Health Organi-zation in Weybridge, UK in December 1996:
“An endocrine disrupting chemical (EDC) is an exogenous substance that causes ad-verse health effects in an intact organism, or its progeny, consequent to changes in endo-crine function.”
“A potential endocrine disrupting chemical (EDC) is a substance that possesses prop-erties that might be expected to lead to en-docrine disruption in an intact organism.”
While a clear definition has been devel-oped and accepted on the international level, it is less clear which substances can actually be classified to fit into this definition. Various jurisdictions and organisations have been attempting to identify those chemicals which are endocrine disrupting. One of the earliest examples of a substances being classified as an endocrine disrupter in hu-mans with direct restrictive regulation result-ing is diethylstilbestrol (DES), a synthetic oestrogen prescribed in the 1950s and 1960s to five million pregnant women for the prevention of spontaneous abortion. It was found that some of the children who had been exposed in the uterus had develop-mental abnormalities, and that some of the girls developed an unusual form of vaginal cancer when they reached puberty. As a consequence, DES was banned in the 1970s.
Since that time, there have been many attempts to develop a concrete listing of EDC. The main difficulty with this task is the lack of scientific consensus. However, upon examination of the various lists generated from a range of countries and organizations, there is widespread agreement on some of the most common EDC. Most persistent organic pesticides (POPs) and similar or-
gan ic con taminan ts l i ke PCBs (polychlorinated biphenyls), and dioxins are considered to be endocrine disrupting. Natu-ral and synthetic hormones like estrogen and estradiol are also included on most lists. Pesticides, plasticizers, surfactants and other industrial chemicals such as phtha-lates, bisphenol A, carbon tetrachloride, nonylphenol, and the food antioxidant buty-lated hydroxyanisole (BHA) are some of the most relevant EDC under current attention. In addition, metals such as arsenic, lead, cadmium, and mercury are contended to have endocrine disrupting properties.
Concerns over the potential impacts of substances that disrupt endocrine function led to the Canadian Environmental Protec-tion Act, 1999 (CEPA) making research on “hormone disrupting substances” a Ministe-rial duty for both Environment Canada and Health Canada. This legal authority resulted in piecemeal research projects and initia-tives to gather more information on EDC. However, in December 2006, the Prime Min-ister, along with the Ministers of the Environ-ment and Health, unveiled Canada's new Chemicals Management Plan. The plan be-gan by taking immediate action to regulate chemicals that are harmful to human health or the environment. A key element in the Chemicals Management Plan is the collec-tion of information on the properties and uses of the approximately 200 chemical substances identified through the categori-zation process as high priorities for action. This information is being used to make deci-sions regarding the best approach to protect Canadians and their environment from risks these substances might pose. Several known endocrine disruptors are included in these batches of substancesand have been made subject to the Chemicals Management Plan.
For chemical substances that have been found toxic after scientific examination, or for those strongly suspected of being danger-ous, steps are taken to control their use, as well as to prevent, reduce or eliminate their release into the environment. This is known as risk management. CEPA defines “toxic” substances as those that enter or may enter the environment at levels or conditions that: have or may have a harmful effect on the environment; are or could be dangerous to the environment that life depends on; or are or could be dangerous to human life or health. Before the government can regulate these substances, they have to be added to the List of Toxic Substances (Schedule 1 of CEPA). Potential EDC already on Schedule 1 include dichlorodiphenyltrichloroethane (DDT), bis(2-ethylhexyl) phthalate, lead,
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Endocrine Disrupting Chemicals
21 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Endocrine Disrupting Chemicals - (continued)
mercury, PBDEs, polychlorinated dibenzodi-oxins, polychlorinated dibenzofurans, poly-cyclic aromatic hydrocarbons and polychlori-nated biphenyl (PCBs). Many of the EDC on Schedule 1 are already being addressed by proposed or adopted risk management tools.
One key example is bisphenol A. Bisphe-nol A is used primarily as a formulant in the manufacture of polycarbonate plastic and epoxy resins. Polycarbonates have wide application in consumer products (e.g. re-peat-use polycarbonate containers), in medi-cal devices, glazing applications, film and the electronics industry, while epoxy resins are used in protective coatings, structural composites, electrical laminates and as ad-hesives and sealants. The classification and assessment process of the Chemicals Man-agement Plan established that bisphenol A meets the criteria to be designated as CEPA-toxic and should be added to the List of Toxic Substances.
As a result, a risk management approach that was published in October 2008 pro-poses that several measures should be im-plemented. These include: banning the im-portation, sale and advertising of polycar-bonate baby bottles made with bisphenol A monomer; developing stringent migration targets for bisphenol A in infant formula cans; establishing stringent migration targets for bisphenol A in canned foods in general; and imposing regulations to minimize the risks from releases of bisphenol A into the environment. In addition, it was proposed to adopt a precautionary approach for bisphe-nol A in food packaging for products in-tended for newborns and infants and will be adopting the As Low As Reasonably Achiev-able (ALARA) principle to minimize expo-sure of these vulnerable populations to bisphenol A.
The first risk management measure re-garding polycarbonate baby bottles made with bisphenol A monomer was officially proposed on 27 June 2009 in the Order Amending Schedule I to the Hazardous Products Act (bisphenol A). If adopted, the Order would add polycarbonate baby bottles that contain 4,4- isopropylidenediphenol (bisphenol A) to Schedule I. This addition would prohibit the advertisement, sale and importation of polycarbonate plastic baby bottles that contain bisphenol A in order to reduce newborn and infant exposure to this substance.
Until recently, the United States has not been particularly active in the classification, assessment or regulation of EDC. Legisla-tion in 1996 resulted in the creation of the
Endocrine Disruptor Screening Program (EDSP). While the EDSP has finally devel-oped a list of priority EDC to assess, it is only considering certain pesticides, which will be subjected to further assessment and potentially new measures. There has been no indication as to what extent the EDSP will expand this list. In September 2009, how-ever, the Environmental Protection Agency (EPA) announced that it will enhance chemi-cal management under existing laws. By enhancing its Chemical Management Pro-gram, the EPA will develop chemical action plans for key substances, including EDC, by reviewing available hazard, exposure and use information. Based on these reviews, the EPA may also require labelling, restric-tion or even ban certain chemicals.
As a result of this initiation, the EPA pub-lished four action plans in December 2009 for phthalates, long-chain perfluorinated chemicals (PFCs), PBDEs in products and short-chain chlorinated paraffins. For PBDEs, as an example, the action plan indi-cates that the EPA intends to initiate rule-making in the Fall of 2010 to add commer-cial PDBE mixtures and/or the congeners they contain to the Concern List under the Toxic Substances Control Act section 5(b)(4) as chemicals that present or may present an unreasonable risk of injury to health or the environment. The intention is to continue to publish one action plan every four months after the first four. An action plan toBisphe-nol A is currently in development as one of the next plans to be published.
The European Union has also begun tak-ing strides of its own to better classify, as-sess, and regulate EDC. In 1999, the Euro-pean Commission adopted a strategy that was in line with the precautionary principle COM(1999)706. This strategy, known as the 'Community strategy for endocrine disrupt-ers;' set out the actions that would be under-taken to address the potential environment and health impacts of endocrine disruption. The first step of this strategy was to create a list of priority substance which would be considered as “suspected endocrine disrupt-ers.” From a total of 564 chemicals that had been suggested by various organisations or in published papers or reports as being sus-pected EDC, 66 substances showed evi-dence of endocrine disrupting activity. Bisphenol A, PCBs, phthalates are included on this list.
Despite the fact that these substances have been classified as key EDC and are being subject to further assessment, the 1999 strategy has been surpassed by Regu-lation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and
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Endocrine Disrupting Chemicals - (continued)
22
Before you buy… due diligence How can you be sure that you not only avoid unforeseen environ-mental liabilities with your new acquisition, but that your new business is a sound and sustainable investment in terms of all EHS issues? Enhesa calls on a wide variety of legal and regu-latory expertise to facili-tate the full range of on-site and desk studies necessary to identify potential environmental liabilities associated with acquisition, leasing and/or divestiture of proper-ties. Contact us for more i n f o r m a t i o n a t [email protected].
Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Restriction of Chemicals (REACH), as adopted on 1 June 2007. Currently, the most relevant part of REACH for the purposes of implementing measures for EDC is the au-thorization component. In order to deal with chemicals of high concern, REACH foresees a special permission system. Substances of very high concern (SVHC) are those that can cause cancer, mutations or problems with reproduction (CMRs), or that accumu-late in human bodies and the environment (i.e. persistent, bioaccumulative and toxic or very persistent and very bioaccumulative), as well as other chemicals which are of ‘equivalent concern.’ These will be put on the Candidate List. Chemicals can only be nominated to the Candidate List by the ac-tion of an EU Member State government, or by the instruction of the European Commis-sion to the European Chemicals Agency.
These substances will have to obtain au-thorisation which is specific to a particular use or application. Also, within this group of substances, some will be subject to stricter conditions in order to obtain an authorisation by decision of the European Commission. For example, the persistent and bioaccumu-lative chemicals can only get an authorisa-tion if the socio-economic benefits outweigh the risks of use, and if there are no safer alternatives. If an authorization has not been obtained, the substance is effectively banned from that specific use or application. Three phthalates, DBP, BBP and DEHP, were placed on the first publication of the Candidate List in December 2008, and their priority ranking for the authorisation proce-dure is currently the subject of a public con-sultation. From 1 June 2011, substances in products which are on the candidate list (subject to certain criteria) will need to be reported to the European Chemicals Agency.
When considering the business impacts resulting from the development of legislation regarding EDC, one needs to first consider that these substances are in a unique posi-tion. Scientific assessment of many of these substances has not resulted in conclusive evidence that EDC should be a priority. There is a lack of consistent classification while classification and assessment meth-ods are being created or amended to ac-count for new research. Despite the scien-tific uncertainty, measures are still being implemented to significantly restrict their use in products operations. On one side, con-sumer concern is acting as a market force driving industry to take the initiative and make adjustments in products and opera-tions. On the other hand, several govern-
ments, such as Canada, are favouring the use of the precautionary principle in devel-oping specific measures. In this regard, such jurisdictions are discounting the lack of cer-tainty and implementing new restrictive measures in light of the potential for these substances to be endocrine disrupting.
As a result of the development of new re-strictions or requirements regarding EDC, a company could expect a potential adminis-trative burden or financial burden. The ad-ministrative burden results from such re-quirements as reporting under the Canadian Chemicals Management Plan or obtaining authorisation under REACH in the European Union. The potential financial burden is much broader. Any required alteration or cessation of operations involving EDC will cause a company to incur financial loses. These requirements could include changes in raw material selection to avoid and reduce EDC, in production process to minimise re-leases of EDC, in design specifications to avoid and reduce the presence of EDC in products being sold and the conditions for purchase of components and parts that con-tain EDC. These measures could also result in a provision to necessitate wastewater treatment to avoid or reduce discharges or to implement measures to address worker exposure to EDC.
In this regard, what can you do to avoid incurring an administrative or financial bur-den for any operations involving EDC? In the first instance, it should be a priority to review the substances with high concern of endocrine disruption and assess if any of these are used in operations or products. It would be advantageous to record informa-tion on, or develop, a management plan for any of the activities involving these sub-stances (i.e. regarding use of EDC in pro-duction of manufactured items or release of EDC in wastewater discharges). Identifying products at risk and attempting to find alter-natives to the use of EDC as far as possible would also be a key step in preparing for the implementation of any new stringent legisla-tion being adopted. Bottom line, affected companies should not wait for government action to begin implementing measures to restrict or eliminate use of EDC. Invoking the idea of the precautionary principle is the way forward for dealing with EDC.
Meghan White EHS Consultant
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North America - (continued)
23 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Essential Use Allowances for 2011 and 2012 22-Dec-2009 [32827]
NSR requirements for fugitive emissions administratively stayed 11-Dec-2009 [28223]
Significant New Use Rules adopted for 14 substances 01-Feb-2010 [33420]
Fire Marshal's rules and regulations 22-Jan-2010 [33538]
CALIFORNIA: Adopted amendments to extend deadlines for meeting retrofit re-quirements for in-use off-road diesel fleets 15-Jan-2010 [30378]
CALIFORNIA: Revised wastewater dis-charge fees for 2010 25-Dec-2009 [32880]
CALIFORNIA: 4 substances added to Proposition 65 List as a result of court order, 23 of 30 chemicals subject to or-der now listed 18-Dec-2009 [30380]
CALIFORNIA: Adopted amendments to require momentary contact devices for all portable power driven augers 11-Dec-2009 [30809]
CALIFORNIA: Adopted continuing edu-cation requirements for Registered Envi-ronmental Health Specialists 04-Dec-2009 [28255]
CALIFORNIA: Adopted low carbon fuel standard for transportation fuels 22-Jan-2010 [29226]
CALIFORNIA: Adopted regulation to re-duce emissions of diesel particulate mat-ter, NOx, and greenhouse gases from diesel vehicles 18-Dec-2009 [27641]
CALIFORNIA: Adopted regulations to reduce greenhouse gas emissions from heavy-duty vehicles 18-Dec-2009 [27643]
CALIFORNIA: Adopted regulations to reduce greenhouse gas emissions from semiconductor operations. 25-Dec-2009 [28621]
CALIFORNIA: Adopted regulations to reduce sulfur hexafluoride emissions in non–semiconductor and non–utility appli-cations 08-Jan-2010 [28619]
CALIFORNIA: Proposed amendments to requirements for workers exposed to vehicular traffic hazards 29-Jan-2010 [33368]
DELAWARE: Adopted amendments to Regulations Governing Solid Waste 13-Jan-2010 [33370]
ILLINOIS: Updated list of substances exempt from VOC and VOM require-
ments 22-Jan-2010 [31841] MICHIGAN: Amendments adopted revis-
ing standards for the storage, transfer and handling of acetylene 22-Jan-2010 [32424]
MICHIGAN: Legislation adopted creating revolving loan for energy efficiency and renewable energy projects 08-Jan-2010 [33451]
MICHIGAN: Legislature passed bill (HB 4377) prohibiting workplace smoking 18-Dec-2009 [32930]
MSHA issued direct final rule regarding notification of accidents 29-Dec-2009 [32998]
NEW JERSEY: Adoption of NJPDES fee assessments for Fiscal Year 2010 01-Feb-2010 [33366]
NEW JERSEY: Fee increase for owners and operators of facilities subject to Toxic Catastrophe Prevention Act 19-Feb-2010 [33365]
NEW JERSEY: Legislation prohibiting the sale and distribution of novelty lighters passed by both Houses 20-Nov-2009 [29184]
NORTH CAROLINA: Adopted revisions to Air Rules 01-Feb-2010 [31391]
SOUTH CAROLINA: Adopted latest edi-tion of nationally recognized codes to update the State
VIRGINIA: Amended construction storm water regulations 04-Jan-2010 [17305]
VIRGINIA: Amended the Virginia Pollu-tion Discharge Elimination System Per-mit Rule to align with federal regulations 01-Feb-2010 [12399]
VIRGINIA: Amendment to definition of Volatile Organic Compound (VOC) using Fast Track process 04-Jan-2010 [28403]
VIRGINIA: Hazardous waste rule revised to align with federal regulations 01-Feb-2010 [12398]
VIRGINIA: Incorporated Federal New and Modified Stationary Sources, and MACT rules by reference 21-Dec-2009 [29094]
(Continued from page 19)
U.S. Securities and Exchange Commission issues guidance for when companies must report climate change risks
24 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
On 27 January 2010, the U.S. Securities and Exchange Commission (SEC) finally put years of public outcry and speculation to rest with the release of an interpretive guidance document explaining how publicly traded companies are expected to assess and disclose business risks associated with climate change. The Commission voted 3-2 in favor of the guidance document that for-mally explains when, and to what extent, publicly traded companies must disclose environmental risks and liabilities associ-ated with climate change to the SEC and shareholders. The SEC's decision marks a noticeable difference in the Commission's receptiveness to climate-related investment requirements from the previous administra-tion, which has been criticized for taking a hands-off regulatory approach before the current financial crisis. SEC regulations require publicly traded companies to disclose material risks to their businesses in certain SEC filings, which are intended to inform investors of a company's financial condition. Specifically, companies must disclose material changes to the busi-ness, material legal proceedings, and analysis of known trends, uncertainties, and financial conditions that could materially affect operations. The law has not changed, but the SEC’s interpretation of the law has. While the SEC's decision is significant, it was not unexpected and is in line with the global trend in favor of requiring companies to disclose environmental and climate change risks. Prior to this decision, many contended that it was unclear whether envi-ronmental and climate change factors con-stituted “material risks” that had to be dis-closed in SEC filings. However, one can trace back the steps leading up to this deci-sion over the past three years and realise that this decision was inevitable. CERES, a network of institutional investors, environ-mental organizations and public interest groups, issued a report in June 2009 find-ing that "about 76 percent of Standard & Poor's 500 companies failed to mention climate change in their annual reports to the commission last year." Less than 10 percent of companies discussed climate change in 2008 Form 10-K, the report said. The report analyzed more than 6,000 Form 10-K filings by Standard & Poor's 500 com-panies between 1995 and 2009 and found what it termed "an alarming pattern of non-disclosure by corporations regarding cli-mate change." Shortly after the CERES report, a collec-tion of investor advocacy groups, state treasury departments and environmental
groups wrote a letter calling for the SEC to address a corporation’s duty to disclose climate change and other environmental, social and governance risks in securities filings. The SEC had refused to take such steps after receiving a similar letter in 2007. However, with a new administration in the White House, this time the SEC issued a response saying it would take a “hard look” at whether climate change risks should be addressed in SEC filings. The SEC has taken a hard look and has now formally explained what it expects from companies in terms of disclosing climate change risks. For European companies, this is nothing new. The Modernisation Directive (2003/51/EC) imposes a duty on European-listed companies to include environmental and other non-financial performance indica-tors in their annual reports. While many countries have provided exceptions to this general rule based on revenue or number of employees, other counties such as France and the United Kingdom extend reporting duties beyond purely environ-mental risks and require publicly listed com-panies to address social and community issues in their annual reports. One notable characteristic of France’s reporting law (arguably the strictest in the world) is that all companies listed on the French Stock Exchange must address environmental risks for all countries where the company operates, not just in France. Other countries around the world are in the process of developing or expanding corpo-rate reporting laws to address environ-mental and climate change risks. For ex-ample, the Costa Rican government is con-sidering a law that would require compa-nies to annually report the measures it takes to protect the environment and to improve the quality of life for its workers and the surrounding community. As pro-posed, the Draft Law on Corporate Social Responsibility (Propuesta de Ley Marco de la Responsabilidad Social Empresarial) would require all companies operating in Costa Rica with 200 or more employees to undergo an external audit to determine a company’s social balance, which would be publicly reported along with a company’s annual economic accounts. Japanese com-panies can also expect to see corporate environmental reporting requirements in the near future. Under the Law on the Promo-tion of Environmental Reporting for Specific Industries (環境情報の提供の促進等による
特定事業者等の環境に配慮した事業活動の
促進に関する法律第二条第四項の法人を定
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25 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Enhesa will be participating in SESHA’s 32nd Annual Symposium & Exposition, which will take place 26-29 April, 2010 in Scottsdale, Arizona. Once again, we will be exhibiting at this annual forum regarding environmental, health and safety issues pertaining to the electronics and other high technology industries. Jack Welsch, En-hesa’s Manager of US Operations, will give a presentation outlining emerging global regulatory trends that will impact the semi-conductor and other electronic industry sectors. Topics covered by the presentation will include: the spread and extension of energy efficiency and climate change track-ing, reporting and emission reduction re-quirements; the global expansion of prod-uct environmental regulations to more countries and affecting more materials and products; the projected massive ramp up in
a growing number of countries of chemical testing requirements with significant impli-cations for cost and availability of materials used in the industry; spread of new man-dates in the area of corporate social re-sponsibility, particularly with respect to stakeholder reporting obligations; and the spread and growth of water management policies and regulations affecting water use rights, water pricing and pressures to mini-mize water use through new technologies and/or product and process reformulations.
For more information about SESHA’s 32nd Annual Symposium & Exposition, please visit http://seshaonline.org.
Enhesa and SESHA teaming up again in 2010
める政令), only public entities are required
to submit annual environmental reports at this time. However, as the duty to disclose environmental risks becomes the rule rather than the exception, Japanese com-panies can reasonably expect to see envi-ronmental reporting requirements extend to the private sector sometime soon. Considering the data from the CERES re-port mentioned above, the SEC’s ruling means that over 75 percent of U.S. publicly traded companies must now begin consid-ering and disclosing climate change risks as they pertain to corporate profitability. This may require companies to adopt pro-cedures and methods for assessing risks and liabilities from climate change in addi-tion to the environmental risks they cur-rently consider, and may lead to further competitiveness between companies to present a more environmentally secure business structure in terms of attracting investment. For those companies who have not considered climate change risks in SEC filings yet, they must begin taking their own “hard look” from a corporate profitabil-ity perspective at how climate change will impact them.
For those who would like to know more about the SEC’s new stance on corporate environmental reporting requirements and other environmental and sustainability re-porting programs from around the world, Enhesa will be presenting a full discussion of the topic at an upcoming webinar – “Sustainability Reporting - It's the Law.” The webinar will take place 6 May 2010 (9:00 AM EST) and 11 May 2010 (11:00 AM EST). To register or to receive more information, e-mail or call Maria Panteris at web [email protected] or +1 202.552.1090. Enhesa also has consulting services avail-able to help assess how well your liability management system is prepared for this new financial reporting requirement and how it might impact issues such as SOX reporting, contaminated properties reserves reporting, and FIN 47 liabilities. To discuss how Enhesa can help you evaluate your preparedness to assess and report climate change related liabilities, contact Gaye van der Eerden at [email protected] or +1 202.552.1090. Frank Skiba EHS Consultant
(Continued from page 24)
U.S. Securities and Exchange Commission issues guidance for when companies must report climate change risks
26 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
The Ministry of Environment, Housing and Development (MAVD) has approved a pro-posal to award the Colombian Environ-mental Label (Sello Ambiental Colombiano - SAC) for sustainable construction. The ini-tiative is innovative amongst Latin American countries, as the existing regulatory instru-ments provide for energy efficiency in build-ings, in products and in processes, but do not regulate construction sustainability as a whole. Interestingly, the proposal seems to approach the topic from two international regulatory perspectives: on the one hand, the existing Colombian environmental label resembles European eco-labelling, like the EU Flower, the German Blue Angel or the Nordic White Swan; and on the other hand, sustainable construction in Colombia would be assessed according to parameters pro-vided by the United States Green Building Council’s (USGBC) Leadership in Energy and Environmental Design (LEED). Al-though attractive, the SAC for sustainable construction proposal deserves further con-sideration, since different approaches might lead to incompatible effects.
Colombian Environmental Label, fol-lowing the E.U. The Sello Ambiental Colombiano (SAC) is regulated in Resolution 1555 of 2005. The SAC label is defined as a voluntarily system of product differentiation that allows identifi-cation of available non-food products, that comply with environmental standards. Envi-ronmental standards must be previously established by technical norms according to the product category. The SAC scheme aims at promoting prod-ucts that are kinder to the environment, fol-lowing the objectives of the European eco-label: the flower logo. In order to reduce negative environmental effects, the products must contribute to the efficient use of natural resources and to a high level of environ-mental protection, with respect to other products of the same category. According to the scope of Resolution 1555 of 2005, the SAC label can only be granted to products and services rendered in the country. If adopted, the SAC label would be awarded to sustainable construction projects. In Europe, the EU flower has not been granted to sustainable construction projects. Rather, the eco-label product group devel-opment has been discussing the possibility of integrating buildings into the eco-label product categories. The EU eco-label report
of March 2009 evidences the outcomes of this debate and details the likely use of the logo in buildings; the different environ-mental, social, economic and safety issues relating to each construction phase; and the validity of criteria for the product group build-ing, among other issues. On top of that, Ger-many has taken a forward step in sustain-able construction labelling by awarding the Deutsche Gesellschaft für nachhaltiges Bauen - DGNB label to more than 16 build-ings.
Sustainable Construction, following the U.S. In Colombia, the Colombian Council of Sus-tainable Construction (CCCS) has under-taken the task of implementing sustainable construction, by ensuring adequate manage-ment during the phases of design, construc-tion, operation and demolition. According to the proposal, the system to be implemented would be the U.S. Green Building Council’s (USGBC) Leadership in Energy and Envi-ronmental Design (LEED). LEED is a United States standard created to evaluate development incorporating green building methods. LEED scorecards have been developed by the USGBC to assign credits to projects based on a range of crite-ria, including site location, energy efficiency, resource conservation and environmental quality. Projects receive certification based on their scores. In the U.S., LEED certifica-tion is available for new and existing devel-opments through LEED New Construction and Existing Buildings programs. According to the U.S. system, buildings complying with LEED can apply for a certifi-cation, which assures that “LEED buildings are constructed as intended.” The LEED certification is the “internationally recognized distinction that a building is environmentally responsible, profitable and a healthy place to live and work.“ Hence, any construction project complying with LEED criteria should be awarded with a certification, award or instrument that confirms that such project is profitable, safe and environmentally respon-sible.
Where to go? If the Colombian proposal adopts the LEED system, the SAC label would have to be redesigned so that compliance with sustain-able construction criteria is evidenced. The proposal on the SAC scheme should take into account all the elements integrating
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Sustainable construction in Colombia: An eclectic approach to European and U.S. regulatory tendencies
27 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Sustainable construction in Colombia: An eclectic approach to European and U.S. regulatory tendencies
sustainable construction certification sys-tem, so that appropriate certifications are awarded to compliant projects. On the other hand, if Colombia intends to apply the SAC label to sustainable construction projects, as regulated in Resolution 1555 of 2005, it should take into account the outcomes of the current debate in Europe on buildings eco-labelling, and the German experience on sustainable construction labelling. Regardless of which system is adopted, whether sustainable construction LEED criteria and certification or buildings eco-labelling, the proposal outcome must ren-der transparent rules to implement an envi-ronmental market instrument in Colombia. By doing so, sustainable construction de-velopers would have verifiable criteria and
tangible instruments to voluntary apply for this innovative eco-label, whilst consumers would have efficient tools to identify envi-ronmentally friendly products and services. The Draft Technical Norm on sustainable construction is expected to be drafted by 2010. Enhesa will be monitoring the pro-gress of the SAC for sustainable construc-tion and will continue to keep clients in-formed of the latest EHS developments in Latin America. Daniel Rincón EHS Consultant
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Enhesa develops Score-Cards and Audit Protocols that can be used by facility and corporate management to identify weaknesses and ensure compliance.
For help with identifying and understanding legal require-ments before they impact your business, please con-tact us for further details. [email protected].
Law 12.187 of 29 December 2009 insti-tutes the National Climate Change Policy of Brazil. While debate rages on over whether or not Copenhagen was effective, Brazil has taken a meaningful step to reduce its projected greenhouse gases (GHGs) emis-sions by approximately 37% by 2020. Much of this reduction will come from cuts in de-forestation rates. In addition, projected an-thropogenic emissions will be decreased through measures such as renewable en-ergy, energy efficiency, and the Brazilian Emissions Reduction Market (MBRE).
Brazil’s commitment, while voluntary, is realistic and, from a practical standpoint, binding. It is realistic because much (if not most) of Brazil has successfully reduced deforestation rates by at least 50% since 2004, thanks to its satellite deforestation monitoring system. The tendency is for monitoring to continue and deforestation to be reduced, if not inverted by 2020. Law 12.187 is politically binding because all the major political parties aspire to portray themselves as environmentally sound. Not meeting the greenhouse gas reduction tar-gets (despite being voluntary), would be too risky for whichever political party happens to be in power.
Law 12.187 also supports the development
of the Brazilian Emissions Reduction Mar-ket (MBRE). How exactly and to what ex-tent the MBRE will be implemented remains to be seen. An increasing number of large companies already report their GHG emis-sions through Brazil’s GHG Protocol Pro-gram, and a growing number of companies participate in voluntary carbon credit mar-kets.
Even though important questions remain about which countries should make larger commitments, how to measure emissions, and how to implement mitigation and adap-tation, the fact is that all seven of the larg-est emitters (China, United States, Euro-pean Union, Indonesia, Russia, Brazil, and India) have committed to what each consid-ers significant reduction targets. To econo-mists, environmentalists, and businesses, Brazil’s National Climate Change Plan may have its weaknesses. Whether it is environ-mentally effective or not, time will tell. How-ever, Law 12.187 has implemented a politi-cally significant and economically achiev-able goal.
Daniel Sotelino EHS Consultant
EHS issues throughout Latin America have become an impor-tant matter for companies to address and understand, due to an increase in regulations and more stringent enforcement ac-tivities. However, all Latin American countries are not the same in their views towards EHS.
Drawing on our expertise in monitoring EHS regulations and conducting
compliance assessments throughout Latin America, Enhesa has analyzed the proposed and passed EHS regulations to identify key EHS requirements which impact busi-ness. In late February 2010, Enhesa continued its successful free webinar series with a spotlight on Latin America.
To request a copy of the presentation, con-tact us at [email protected].
Latin America EHS Update Enhesa free webinars on the latest developments in chemicals regulations
29 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
While Brazil has not changed its waste gen-erator liability since adopting Law 6.938 in 1981, it has updated and altered require-ments for generators. Most recently, the Brazilian National Council on the Environ-ment (CONAMA) adopted CONAMA Reso-lution 420/2009, establishing guidelines and criteria for the management of contaminated sites. CONAMA Resolution provides for the creation of soil quality criteria, guidelines for the remediation of contaminated sites, and contaminated sites record-keeping at the local level. CONAMA Resolution 420/2009 requires facilities with potential to cause soil and groundwater contamination to have a monitoring program for soil and groundwater
quality in place and to submit a conclusive environmental audit report on soil and groundwater quality to renew their environ-mental licenses or prior to their permanent closure.
These and other issues will be discussed at the CHWMEG Latin America Global Focus Seminar in April. See “Enhesa and CHWMEG teaming up again in 2010”, article on page 3.
Daniel Sotelino EHS Consultant
Brazil Updated soil contamination regulations
Argentina Deadline for the installation of a sleeper
cab in motor vehicles used in the inter-state or international transport of goods extended 08-Jan-2010 [33444]
Law 26.556 and Decree 2040/2009 ap-proving the Convention on Protection of the Underwater Cultural Heritage adopted 16-Dec-2009 [32894]
Law 26.562 establishing minimum envi-ronmental requirements for burning of vegetation for land clearing adopted 16-Dec-2009 [32910]
List of medical examinations to be in-cluded in the occupational risks system adopted 14-Jan-2010 [33458]
National Registry for Repair and Modifi-cation Workshops for Passenger and Cargo Vehicles of Federal Jurisdiction approved 21-Dec-2009 [33094]
National Strategy for Prevention and Control of non-transmissible diseases adopted 29-Dec-2009 [33247]
Norm 7.11.1 on individual permits for operators of industrial scintigraphy equip-ment reviewed 07-Jan-2010 [31135]
Procedure to apply for an authorization to use certain controlled substances adopted 30-Dec-2009 [33249]
Provision 6254/2009 establishing require-ments for domestic products in order to ensure quality and safety levels adopted
18-Dec-2009 [32914] Revision 3 of Standard AR 7.9.1 on the
operation of gammagraphy industrial equipment adopted 18-Jan-2010 [31463]
BUENOS AIRES: Provision 1692/09 es-tablishing the obligation to contract an insurance policy before requesting envi-ronmental permits adopted 23-Dec-2009 [32916]
Chubut: Law on municipal solid waste management adopted 11-Jan-2010 [33446]
Chubut: Measures to prevent forest fires adopted 26-Jan-2010 [33461]
Brazil Draft Resolution on listing and informa-
tion sharing for controlled substances under Mercosul open for public consulta-tion 01-Dec-2009 [32924]
Established criteria for auto emissions control plans 25-Nov-2009 [32920]
Established medication tracing and con-trol system 12-Jan-2010 [32995]
Established presumed credits against Industrial Product Taxes for solid waste acquisition for industrial use 23-Dec-2009 [33382]
Established sustainability criteria for gov-ernment procurement 19-Jan-2010 [33445]
Legislation on Federal Technical Register
(Continued on page 30)
Central & South America - (continued)
30 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Central & South America (continued)
for Potentially Polluting Activities amended 03-Dec-2009 [11546]
National Climate Change Plan (PNMC) adopted 29-Dec-2009 [27465]
National Fund on Climate Change estab-lished 09-Dec-2009 [32921]
Ordinance on procedures to obtain ap-proval certificate for PPE reviewed 02-Dec-2009 [11931]
Published proposed Mercosul resolution on anti-microbial products 01-Dec-2009 [33011]
Resolution on the transport of dangerous goods revised 20-Jan-2010 [7003]
CONAMA Resolution on soil contamina-tion adopted 28-Dec-2010 [11959]
Rio de Janeiro: Altered fees under the State Register of Potentially Polluting Activities law 29-Dec-2009 [27018]
São Paulo: Established criteria for envi-ronmental compensation 26-Nov-2009 [32923]
São Paulo: Listed activities subject to CETESB installation licensing for pur-poses of ICMS tax contributor registra-tion and alteration 27-Nov-2009 [33018]
Chile Parameters to estimate environmental
flow adopted 15-Dec-2009 [32889] Regulation on the management of waste
from health care facilities adopted 04-Dec-2009 [32893]
Technical norm on safety of electrical appliances for households adopted 14-Jan-2010 [33335]
Colombia Regulation on radioactive waste issued
05-Jan-2010 [33261]
Dominican Republic New Constitution adopted 26-Jan-2010
[32730]
Ecuador Agreement on the import quota for ozone
depleting substances issued 20-Jan-2010 [33343]
Third Revision of Potable Water Require-ments published 19-Jan-2010 [33341]
Peru Law on pharmaceutical products adopted
26-Nov-2009 [32352] Water quality standards adopted 19-Dec-
2009 [31525]
Puerto Rico Law restructuring and unifying the proc-
ess for evaluation and granting of li-censes and permits adopted 01-Dec-2009 [29931]
Uruguay Technical requirements for low voltage
cables and electrical conducts adopted 31-Dec-2009 [32817]
Venezuela Rules on the organization and operability
of the National Register on Watercourse Users adopted 21-Jan-2010 [33245]
(Continued from page 29)
Actualmente Enhesa se encuentra evaluando la posibilidad de lanzar el Flash de Enhesa en idioma Español.
¿Sería esto de utilidad para usted o para su empresa? Por favor háganoslo saber a: [email protected]
Enhesa is considering launching the Enhesa Flash in Spanish. Would this be of interest to
you or any of your colleagues? Please let us know by emailing us at: [email protected]
31 Enhesa Brussels Washington Enhesa Flash 52 - Mar 2010 © Enhesa 2010
Enhesa webinar program
Enhesa webinars focus on topics important to EHS professionals interested in global com-pliance assurance. Webinars are designed to provide you with information that you can use to enhance your own knowledge and your company’s environmental programs If you would like to attend these webinars, email Maria Panteris at [email protected].
Upcoming Webinars
International Water Use Policies Regulatory Issues and Trends
Are you ready for increasing water scarcity?
25th & 30th of March 2010
Sustainability Reporting - It’s the Law
Where is sustainability reporting legally required? What are the future developments for regulation?
6th & 11th of May 2010
Previous Webinars
A Global Round-Up of Regulations on Batteries (January 2009) Substances of Very High Concern (SVHC) (April 2009) Occupational Exposure Limits – European Harmonization? (June 2009) Waste Producer Liability in China (August 2009) Auditing in a Troubled Economy (September & October 2009) Global Pollutant and Greenhouse Gas Reporting Programs (November 2009) EHS Forecast 2010 (December 2009) Endocrine Disrupting Chemicals (January 2010) Latin America EHS Update (February 2010)
For a copy of these presentations or access to the recording of a past webinar, contact Enhesa at [email protected].
24-25 Mar 2010, IOSH 10 Health & Safety: Making the Case, Glasgow, Scotland
Enhesa’s Paul Beatley will be presenting Complying with health and safety requirements de-spite tighter budgets, with a particular focus on how global companies can ensure compliance across international operations.
For further info, please visit www.ioshconference.co.uk.
29-31 March, GlobalChem Conference, Baltimore, Maryland Enhesa will be exhibiting at Globe 2010, in partnership with BNA. For further info, please visit http://www.americanchemistry.com/.
13-15 April 2010, CHWMEG, Nashville, Tennessee Enhesa’s Eduardo Molina Quintero and Daniel Sotelino will be presenting at the CHWMEG
Global Focus Seminar on Current and Emerging Waste Producer Liability Schemes in Latin America.
For further info, please visit www.chwmeg.org/html/agenda/2010-04latin_agenda.html.
19-20 April 2010, AAC Conference, Alberta, Canada Enhesa will be exhibiting. For further info, please visit http://www.auditingcanada.com/events/17
26-29 April 2010, SESHA, Scottsdale, Arizona Enhesa will be exhibiting. For further info, please visit http://seshaonline.org/meetings/2010
25-28 N-Expo 2010, Tokyo, Japan Enhesa will be exhibiting. For further info, please visit http://www.nippo.co.jp/eng/n-expo010/ 8-10 September 2010, Fall Auditing Roundtable, Philadelphia,
Pennsylvania Enhesa will be exhibiting. For further info, please visit www.auditing-roundtable.org
13-15 October 2010, NAEM 18th Annual EHS Management Forum, Indianapolis, Indiana
Enhesa will be exhibiting. For further info, please visit www.naem.org
30 November 2010, Pollutec, Lyon, France Enhesa will be exhibiting. For further info, please visit www.pollutec.com
Upcoming events and presentations
Washington: Paul Cullen Beatley, Enhesa President 1411 K Street, NW Suite 503, Washington, DC 20005, USA Tel: +1-202-552.10.90, Fax: +1-202-747.28.74
Brussels: Thierry Dumortier, Enhesa Director 15 rue du Mail, B-1050 Brussels, Belgium Tel: +32-2-775.97.97, Fax: +32-2-775.97.99
http://www.enhesa.com [email protected]
32 Enhesa Brussels Washington
© Enhesa 2010
The Enhesa Flash is distributed free of charge. For subscriptions, please go to http://www.enhesa.com/service/flash.aspx
Enhesa — global EHS compliance assurance support to industry
Enhesa is an international environmental, health and safety consulting firm, providing EHS regula-tory compliance assurance support to businesses worldwide. Over the past 20 years, we have devel-oped a range of products and services tailored to our clients’ needs. Our team of highly trained and experienced, multilingual consultants is in a unique position to keep you ahead of the latest regula-tory and policy issues as they unfold in over 130 countries and jurisdictions around the globe.
Enhesa Flash 52 - Mar 2010
