International EHS Protocols: Content Description

Last Revised May 2019

General
Environmental, Health and Safety (EHS) protocols are available for several global jurisdictions. They
include environmental regulations, as well as occupational safety and health requirements. The
protocols focus only on regulatory requirements. Guidance documents and related "standards" are
also included only in those cases where they are publicly available without any copyright issues for
reproduction and are considered mandatory "requirements” due to being directly referenced in the
legislation.

These protocols are limited to addressing only those national (or state/provincial, as applicable) EHS
requirements that have site-specific application to day-to-day, land-based manufacturing operations.
As a result, various EHS-related legislation is specifically excluded from this discussion. For example,
there is a substantial body of legislation that only applies to government entities and not the private
sector. Other legislation is focused on specific non-manufacturing industrial sectors (i.e., use of
protected natural areas and forestlands; requirements related to agriculture). Such legislation is
excluded from the scope of this protocol. Finally, these protocols do not cover requirements that may
be imposed specifically on mining activities, or offshore and maritime- related activities.

Introductory Section
Most of international protocols contain a 20-30-page introductory section. Introductory chapters of
these international EHS protocols provide a detailed discussion of the country, history and
enforcement of environmental health and safety legislation, as well as other information on that
country’s business practices and customs. The Introductory section contains discussion of the
following topics:

• Country Overview: Within this section, there is further discussion of the legislative process
and the identity of the environmental and occupational health and safety authorities,
including the scope of their respective roles.

• Enforcement Practices: This section discusses how the government deals with
enforcement, including what are the available options relative to administrative actions,
civil liability, criminal, and strict liability.

• Audit Privilege: This section addresses the extent to which audit privilege exists in the
country. If there is no statutory privilege (which is often the case), this section also
discusses whether an audit report be protected through having the audit and the audit
report conducted through an attorney (i.e., can the information be protected through
"attorney-client privilege").

• Access to Information: This section discusses access to governmental information. If there

is access to such information, under what conditions is it granted? In the U.S., for example,
we can access governmental records through filing a Freedom of Information request (a
written letter).

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 • Property Transfer Requirements. This section discusses legislation involving the transfer or
businesses or property, with specific reference to environmental due diligence requirements
as specifically embodied in legislation (beyond "caveat emptor"), including affirmative
obligations to disclose information about environmental problems.

• Contaminated Land: This section focuses on specific regulations concerning the cleanup of
contaminated properties.

• Reporting of Spills and Releases: This section discusses regulations involving the reporting
of spills and chemical releases to environmental authorities.

• Other Useful Information: This section contains a list of EH&S federal agencies, including
addresses and telephone numbers. Information is also provided on where one can obtain
copies of environmental, health and safety regulations, including addresses and telephone
numbers.

• Description and Organization of Protocol: This section describes the overall scope and
organization of the protocol, including limitations. It also identifies who provided the legal
support for the development of the protocol.

International Protocol Organization and Content

Following the Introductory Section, each of the protocols is divided into 16 distinct sections. Each of
these sections is further sub-dividing into topic specific sub-sections, which provide a detailed
checklist of requirements related to the relevant topics. The requirements are structured in question
format such that a “yes” answer indicates compliance/conformance. Each requirement also includes
a regulatory reference/citation. Many requirements include guide notes to assist the auditor with
understanding the full scope of the requirement. As relevant, definitions are provided at the
beginning of each sub-section.

Another important feature to note is that an applicability checklist is provided for use prior to
conducting the audit. The applicability checklist poses questions for each of the sub-sections as
described above that allow the auditor to refine the list of requirements for a particular audit.

A broad outline of each of the 16 main sections is provided below:

Section 2.0: General Environmental

• Environmental impact statements (EIS) and assessments (EIA) for new construction and facility
modifications, Environmental aspects of planning permissions
• Multi-media operating permits/licenses (such as Integrated permits)
• General multi-media environmental monitoring programs
• Energy conservation / efficiency of buildings, including auditing (energy audits) or assessment
requirements
• Environmental fees/taxes. Such fees/tax is covered if this is a stand-alone requirement, not
related to registration/reporting. Fees for permits, etc., are not covered

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 • Radiation Ionizing/Non-Ionizing– environmental aspects (occupational aspects are covered in
Section 15.0)
• Sector-specific general environmental program requirements (reference only)
• General environmental-related programs associated with building closures or cessation of
operations (notification, contaminate assessments); high level-presentation; description of
regulatory basis should also be discussed in the Introduction
• Natural resource use approvals/coastal protection programs
• Species protection requirements, as specifically related to site construction or operations
• Environmental release/inventory reporting (i.e., Canadian National Pollutant Release Inventory
Reporting or European EPRTR) or general environmental disclosure reporting
• Requirements specific to site environmental organizational structures (i.e., identification of
Environmental Coordinators, Environmental Committees – not related to teams/planning
groups responsible for a particular permit or media compliance program
Note: Genetically Modified Organisms (GMOs), carbon sequestration, and application procedures for
EIS/EIA and permits are excluded

Section 3.0: Air Emissions

• Permit and license requirements
• Performance standards, including emission standards (i.e., fugitive emissions, dust,
combustion byproducts, SO2, NO, particulate emissions, toxic air pollutants, volatile organic
compounds)
o Note: “Ambient” air quality standards will not apply if they are not enforceable on a
site-specific basis
• Emissions monitoring and reporting
• Response to upset conditions
• Notification of excess emissions
• Source-specific standards (include those that might exist at a broad range of operations –
boilers, generators, emergency back up systems)
• Mobile sources
• Ozone-depleting substances
• Greenhouse gas (GHG) reporting (but not GHG trading schemes)

Section 4.0: Solid and Hazardous Waste (except PCBs and Asbestos, both of which are separately
covered below). Note: Focus is on generator (producer) requirements plus on-site treatment and
disposal of waste, including incineration. Lesser /no emphasis on off-site treatment or disposal by
Commercial facilities.
• Permits, licenses, registrations, manifests, notifications for Generators
• Manifests/consignment notes Duty of Care obligations
• Performance standards relative to handling, storage, and disposal of waste (transport of waste
covered in Section 14)
• Landfilling of Wastes ( disposal systems owned/operated by the facility for disposal of
onsite generated waste – not commercial or municipal landfills)
• Waste incineration (air emissions requirements are covered in Section 3.0)
• Monitoring/Recordkeeping and reporting
• Emergency response plans and equipment

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 • Export/Import of hazardous waste (however the import of waste is not covered when product-
related)
• Waste packaging requirements
• Specific waste requirements: Used batteries, Electrical and Electronic Equipment, End-of-life
vehicles, contaminated debris, Mercury waste
Note: Radioactive wastes such as from nuclear power plants are not addressed; medical waste that
may be radioactive or radioactive waste from small medical/QA devices are covered.

Section 5.0: Water Resources

• Water Supplies (as it relates to the private Abstraction of Drinking and Process Water)
• Operation of On-Site Wastewater Treatment Systems Wastewater Discharges (to ground,
to water bodies, to public sewers)
• Stormwater runoff and discharges
• Surface water impoundments, dam and canal management
• Water diversion/water collection systems (excludes requirements related to industrial
hygiene impacts such as Legionella’s Disease)
Relative to each of the above topics, the protocol addresses: permit and licensing requirements,
performance standards to be achieved; periodic monitoring and reporting requirements; and
responses to excursions or upset conditions.

Note: Relative to water quality standards to be achieved, “ambient” standards are not included
unless they are enforceable on a site-specific basis.

Section 6.0: Above and Below Ground Tank Management

• General tank design requirements (single or double walled; cathodic protection; leak detection
systems, etc., plus references to applicable design codes)
• Installation requirements and pre-operational testing
• Permit, registration, licensing, and notification requirements
• Periodic maintenance and monitoring requirements
• Requirements in response to a release
• Closure and removal requirements
Note: Chemical content-related requirements will be included in Section 16, Chemical Management

Section 7.0: Community Noise

• Standards to be achieved
• Monitoring requirements
• Reporting requirements in response to noise upset
Note: Product-specific noise standards are not included (e.g., standards related to manufacturing of
lawn mowers, or vehicles) unless the subject facility must achieve the product standard.

Note: Occupational Noise is covered separately in Section 15, Industrial Hygiene

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Section 8.0: PCBs (including Air, Waste, and Industrial Hygiene requirements as they pertain
to PCBs)
• Threshold concentrations of PCBs, below which the legislation does not apply, or equipment
not considered as containing PCBs
• Licensing, permit, registration, or notification requirements
• Labeling requirements
• Inventory, monitoring or inspection requirements
• Storage, removal (particularly equipment), and disposal requirements
• PCB bans, particularly regarding electrical equipment

Section 9.0: Asbestos (including Air, Waste, and Industrial Hygiene requirements as they pertain to
asbestos)
• License, permit, registration, or notification requirements
• Inventory, monitoring or inspection requirements Removal or abatement
requirements
• Storage and disposal requirements
• Asbestos bans
• Hygiene practices regarding workplaces where asbestos is used in manufacturing process
• Hygiene practices regarding removal of asbestos containing building materials
• Medical surveillance
• Personal protective equipment
Note: Requirements pertain to manufacturing of products containing asbestos, as well as presence
and/or removal of asbestos containing building materials. Asbestos mining is excluded.

Section 10.0: General Health and Safety

• General workplace requirements such as vehicle traffic rules, load rating for floors, etc.
Requirements to reduce employee exposure are in Section 15.0.
• Worker Committees/Safety Committees/OHS Persons-Experts
• First Aid/Medical Services (but not medical monitoring, which is included in Chapter 15,
Industrial Hygiene Section)
• Accident and Injury Reporting and Record Keeping
• General Workplace Risk Assessments (focus is on risk assessments for general
plant hazards; risk assessments focusing exclusively on chemical exposure risks
are included in Chapter 15, Industrial Hygiene Section)
• Multi-topical emergency planning and evacuation planning (fire, storm, earthquake, and
chemical) [single topic emergency and evacuation planning (i.e., fire, or chemical) is included
in either Chapter 13, Fire Safety Section or Chapter 16, Chemical Management Section, as
applicable
• Safety Signs and Markings
• Young workers/Pregnant and Breastfeeding workers. Focus is on health and safety aspects
such as types of work that young workers or pregnant women cannot perform, mandatory
breaks, nursing breaks, working hours, etc. Issues related to labor law such as remuneration,
vacation days, etc. are out of scope.

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Section 11.0: Equipment, Machine, and Electrical Safety
• General tool and equipment safety
• Machinery and machine guarding
• Welding, Cutting, and Brazing
• Pressure Vessels (including boilers), Reactors, and Piping
• Electrical Safety
• Work Practices, including lockout/tagout

Section 12.0: Material Handling and General In-Plant Safety

• Manual lifting and handling procedures
• In-Plant Powered Vehicles
• Lifting equipment such as forklifts, manlifts, hoists, elevators to carry people and/or loads
• Other Equipment (as applicable—limit to important ones)
• Walk and Working Surfaces (focus on fall protection)
• General access and egress (those related exclusively to evacuation in the event of a fire are
covered under Chapter 13, Fire Safety Section)
• Ladder Safety
Confined Space Entry Procedures
Note: Handling and use of explosives is excluded.

Section 13.0: Fire Safety

• Fire Permits and Registrations
• Emergency Evacuation Plans and Drills (fire predominantly; otherwise goes into Chapter 16,
Chemical Management)
• Fire Suppression Equipment and Procedures
• Emergency Alarm Systems
• Fire brigades and emergency response teams
• Means of Egress specifically in event of fires (general access and egress covered in Section
12)
• Storage of flammable and combustible liquids

Section 14.0: Transport of Dangerous Goods (Road, Rail)

• Definitions of Dangerous Goods
• ADR Requirements (European Agreement concerning International carriage of dangerous
goods by road), if the country is a signatory to the agreement
• Packaging and Labeling Requirements
• Spill Response Requirements
• Emergency equipment requirements
• Driver and general vehicle requirements
• Reporting Requirements
Note: Stand-alone legislation on the transport of explosives is not applicable.

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Note: This section intended to focus on plant requirements as they relate to getting regulated
dangerous (hazardous) goods ready for transport to customers or other plants, including vehicle
placarding. The section is not to cover broader common carrier requirements or on-road safety.

Note: Requirements related to driver safety such as driving time, breaks, recording of driving time
(tachographs) etc. are out of scope.

Section 15.0: Industrial Hygiene

• General (light, heat, dust, provision of drinking water, washrooms, rest areas,
etc.)
• Exposure to Hazardous substances, including materials, chemicals, and biological
agents in the workplace, including related exposure standards and exposure
related risk assessments
• Medical Surveillance
• Radiation (non-nuclear power plant related)
• Respiratory Protection and Other Personal Protective Equipment
• Occupational noise standards, including monitoring requirements
• Cooling tower/water source requirements and prevention of Legionnaires Disease or other
water-borne diseases
• Ergonomics – general requirements

Section 16.0: Chemical Management

• Pre-manufacturing/registration/importation notification requirements for new and
existing substances
• Packaging and labeling requirements (for substances used on the factory floor)
• Material safety data sheet requirements (to be supplied to customers and for use in the
workplace)
• Periodic record keeping and reporting obligations (regarding new and existing substances)
• Permits, licenses and authorizations for storage of dangerous/hazardous
materials
• Storage of dangerous/hazardous materials
• Storage of compressed gases
• Carcinogenic substances (registrations, notifications, prohibitions; all other aspects go into
Section 15, Industrial Hygiene)
• Prohibited or restricted substances and chemicals (except ozone depleting substances,
which are covered in Section 3)
• Emergency response and contingency planning (i.e. Seveso-type)
• Spills and releases

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Section 17.0: Construction Work Site Safety
• Permits and licenses
• Construction management systems
• Awareness training
• Equipment, machine, and electrical safety
• Ladders and scaffolds
• Walking and working surfaces
• Excavations
• Demolition

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