Occupational Safety and Health Risk Management Support
This service evaluates occupational health and safety (OHS) measures and proposes improvements. OHS refers to situations in the workplace. It is the responsibility and obligation of employers to provide workers with a workplace where their physical and mental health is guaranteed.
In terms of OHS risks, paying attention to the safety, work environment, compliance, etc. situations of your own locations, and those of your suppliers, will lead to a reduction of risks related to litigation and your firm’s reputation, while helping to maintain a stable supply chain.
When is OHS risk management required?
As a result of requests from companies headquartered in Europe and North America, or following internal audits, there are many cases when domestic and foreign-operating Japanese companies, and overseas and foreign companies based in Japan, are forced to comply with OHS risk management programmes. As a result of requests from companies headquartered in Europe and North America, or following internal audits, there are many cases when domestic and foreign-operating Japanese companies, and overseas and foreign companies based in Japan, are forced to comply with OHS risk management programmes.
- Business partners or your own head office in Europe or the US has requested OHS education be conducted at locations in Japan.
- A business partner has come to audit a manufacturing site in Malaysia.
- An internal audit of a Thai location found improvements in OHS, but no one could confirm the status of local legal compliance.
In Japan, people have traditionally believed ‘safety > hygiene’, based on the idea of ‘safety first’, but when an audit is conducted by a business partner or other body, both hygiene and safety aspects are confirmed. Outside eyes are becoming stricter year by year, even in Asian countries where many Japanese manufacturing industries are expanding.
In some cases, mainly for companies headquartered in Europe and U.S., it is not only the subsidiaries of their overseas locations, but also the factories of their suppliers, who are audited and need to be provided guidance for improving their OHS situation.
Common items in terms of environmental health and safety
In the Japanese manufacturing sector, ‘safety’ and the ‘environment’ are often managed by different departments, but in foreign-affiliated companies, the ‘risks’ of both the environment and OHS are often handled by the same department as environmental health and safety (EHS) risks.
Risk is expressed by the ‘probability of occurrence of harm’ x ‘severity at the time of occurrence of harm’. Regarding concerns about environmental contamination or personal injury, countermeasures are implemented first for the one with the higher risk.
One potential source of harm is anything defined as a ‘hazard’. In OHS risk management, taking appropriate measures against hazards is required.
Hazard Countermeasures Priority
Regarding the concept of dealing with hazards, Clause 8.1.2 of ISO 45001 also mentions the time to reduce risk in the following order of priority (elimination, substitution, engineering controls, administrative controls, personal protective equipment).
Flow of OHS risk management support
EnBio provides support services that meet the needs of our customers regarding OHS risks at their domestic and overseas locations.
In particular at overseas locations, it is possible to diagnose risks and propose improvements in consideration of the standards required by suppliers, from viewpoints considering local legal compliance, ISO 45001: 2018, ‘Compare with Japanese standards (Occupational Safety and Health Law)’ and so on.
During the M&A phase, there is also an example of evaluating OHS risks of a target company. EDD is implemented to understand the environmental risks of the target site and to evaluate them appropriately. EDD organises information that can have a significant impact on transactions, such as soil contamination risks, emissions, wastewater concerns and legal compliance.
During M&A DD, EHS risks are often required to be integrated into the evaluation of OHS.
What corporate risks are related to mental health?
When considering the OHS risks for a company, it is necessary to keep in mind not only employees’ physical health, but also their mental health. Compared to environmental and safety laws and regulations, legal regulations concerning metal health are still developing, but these laws and regulations have become stricter in recent years.
As a result of the above, mental health OHS refers not only to ‘clearly inappropriate conditions such as bullying or power harassment’ and ‘those with numerical standards such as working hours’, but also conditions that are difficult to understand at first glance and which fail to meet legal compliance issues pointed out by audits.
Example of inappropriate operations related to stress checks
According to Japan’s Industrial Safety and Health Law, all firms with 50 or more workers are required to carry out stress checks. These checks aim to prevent mental health problems among workers by encouraging them to be aware of stress and to prompt firms to improve elements of the working environment that cause stress. The results of these stress checks are delivered directly to the worker by the doctor, public health nurse or other professional who has conducted the test. It is illegal to provide these results to the operator of the business without the consent of the worker who has been tested.
It is not enough for a company only to provide workers the opportunity to take a test. If a firm is not operating properly, it is not legally compliant. For example, ‘the results were notified to managers in the human resources and general affairs department, and doctor interviews were recommended to highly stressed people’ is a case that cannot be said to meet legal compliance.
In addition, care must be taken to avoid notification methods that may presume that the person is highly stressed. however, in some cases, test-takers can easily find out the names of highly stressed people from the order of destination of e-mail which includes information on mental health. Such a situation should be avoided by taken into proper consideration.
In this way, even at Japanese worksites where Japanese companies should have a good understanding of local laws and regulations, there may be situations where issues are pointed out by external audits.
Q&A
- Why do you need to check the OHS risks of a supplier?
- OHS is recognised by companies with offices in multiple countries as a business risk. In the latter half of the 1990s, low-wages, long working hours and child labour were discovered in factories in Indonesia and Vietnam that manufactured products for US apparel manufacturers. The corporate social responsibility reputations of the outsourcing companies were severely criticised, mainly by NGOs, and a global boycott emerged that provided many firms the opportunity to actively address working environment at supplier's factory.
In addition, audits may be conducted as "human rights DD" due to concerns about cases that may develop into ethical issues, as in the example above. - Are there any international standards that can be used as indicators when assessing employees’ mental health?
- In June 2021, a new ISO 45003:2021 (Psychological health and safety at work - Guidelines for managing psychosocial risks) was released. This standard provides guidelines for managing mental health and addresses many areas that can affect the psychological health of workers, including ineffective communication, excessive pressure, weak leadership, and organizational culture.
- How do you assess OHS risk for office bases?
- The first step is to confirm that the office meets the legal requirements of the country or region in which it is located. In Japan, we generally conduct on-site inspections to verify the current status of the office, which may involve such issues as brightness of the office, number of break rooms and restrooms, etc.