Do You Really Need an HSE Legal Register?

There are, at least to me, a surprising number of companies operating without any real idea of their worker health & safety and/or environmental regulatory obligations.  This is particularly true in developing countries, where there are undoubtedly many reasons for this lack of understanding of the HSE requirements:

  • blissful ignorance, i.e., lack of awareness of the requirements
  • little or no concern about worker health and safety and/or environmental issues
  • little or no concern about the consequences of not being compliant with the regulations, i.e., lack of enforcement by the regulators
  • lack of people and/or resources to compile such a register
  • concerns about the cost to develop or acquire such a register

Equally surprising to me, is that, by far the majority of companies that do have some sort of HSE legal register have one that is incomplete and/or out-dated.   

In this short blog post I will discuss whether or not your really need an HSE legal register, or is this simply a ploy by consultants to sell services and vendors to sell products!

What is an HSE Legal Register?

A legal register is nothing more than a compilation of the laws and regulations that apply to HSE issues at your business.  These can be compiled and stored in any manner you choose, from index cards to fancy web-based systems.  You can purchase the HSE legal register from many vendors or consultants, including Redlog Environmental.   Or, as I suggested in previous blog post you can build one yourself.  Read How to Build Your Own HSE Legal Register where I provide a step-by-step process for developing a simple spreadsheet HSE Legal Register and a downloadable file to serve as a template. 

The register on its own is meaningless.  Rather, it is simply a tool to help you and your company manage a business issue – namely compliance with legal and regulatory requirements.   Nothing more.  Nothing less.  What is more important is what you do with it.   Check out my previous blog post for compliance auditing for more discussion on that critical issue - How to Carry Out Your Own HSE Compliance Audit.

What Makes an Effective HSE Legal Register?

As I noted above, an HSE Legal Register comes in many forms.  In my opinion, the form is not important.  What is important, however, is that the register is:

  • complete, i.e., includes all of the laws, regulations, ministerial orders, etc. that apply to your company’s operations
  • as simple as possible, i.e., remove the complex legal jargon so that the requirements are clear to all
  • updated regularly, e.g., real-time, monthly or quarterly update
  • supported by people knowledgeable in the requirements and how they affect your company’s operations, e.g.., HSE manager, but can also be consultant, in-house legal, or others

OK, But Do I Really Need One?

First, I know of no legal obligation anywhere in the world that requires you to have an HSE Legal Register.  So strictly speaking, no, you really do not need one.

But, there are numerous very good reasons for having an HSE Legal Register:

  • This is a direct requirement of virtually all corporate health and safety or environmental management systems, e.g., ISO5001, ISO14001, ISO18001, in-house HSE management system, etc.
  • If your company has operational activities with material HSE operational risks, the the register provides the basis for corporate liability protection, as it is needed for performing a compliance audit.
  • If something goes wrong and your company has been operating outside of the legal HSE requirements, this can directly affect you. I strongly suggest that you find a way to protect yourself from the consequences.  After all, this is one of the few jobs where the consequence of failing can mean that you spend time in prison!
  • And, last but certainly not least, compliance with HSE laws and regulations will help protect your workers and impacts on the environment.

If you want to more information on HSE Legal Register and how it can apply to your facility, please contact us.  We are constantly in the process of updating our registers for our clients, with the goal to make them as simple-to-use, effective and inexpensive as possible.

Thanks for reading.  Keep safe.  Be healthy.  Respect your environment.

I hope that you will bookmark the blog, share it with your colleagues and visit the blog frequently because you find it informative and helpful.  I value your feedback and suggestions for future topics.

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Randall D. Shaw, Ph.D.
Posted in Asia, Environment, HSE, Industrial Hygiene, Laws and Regulations, Middle East, Occupational Health, Worker Safety and tagged , .

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