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Challenges and insights of creating a safety program abroad
FEATURE
Challenges and insights of creating a safety program abroad Establishing business and academic endeavors abroad is an exciting and extremely challenging undertaking. This is especially true when setting up ventures that have the complications of an academic institution complete with world-class research laboratories and a diversified faculty, staff and student population from over 50 countries. This article will take the readers through many of the challenges associated with setting up an institution abroad from the start-up to the fully operational phases. The authors will examine an expanded view on ‘‘Duty of Care’’, security challenges, hazardous material experiences, cultural challenges, and crisis preparedness programs; all while giving a first hand account of tackling these different issues far removed from the parent campus.
By Marne Smith, Brandon S. Chance, G. Benjamin Cieslinski INTRODUCTION
Every year businesses and academic enterprises branch out and expand into the farthest regions of the world. For the officials and managers tasked with setting up this type of endeavor it can be exciting, motivating, and energizing as you dive into the local culture and cuisine. But it can also be convoluted, complicated, and frustrating as Marne Smith, M.Sc., CHMM, CET is the Director of the Office of Building Operations and HSSE, Texas A&M University at Qatar, PO Box 23874, Doha, Qatar (e-mail: [email protected]). Brandon S. Chance, M.S., CCHO is the Chemical Safety Program Manager with the Office of Environmental Health and Safety, Princeton University, 262 Alexander Street, Princeton, NJ 08540, United States (Tel.: +1 6099551289; e-mail: [email protected]). G. Benjamin Cieslinski is the Laboratory Manager with the Department of Science, Texas A&M University at Qatar, PO Box 23874, Doha, Qatar (e-mail: benjamin.cieslinski@qatar. tamu.edu).
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you attempt to navigate unfamiliar waters of foreign concepts of responsibility and legal quagmires. Successful managers of foreign ventures must have an in-depth understanding of not just the culture in which they will operate, but also an understanding of the complexities and problems that will arise as a result of operating in a foreign locale. One can assume that working in a foreign locale will require learning the local laws and regulations to develop an effective operation. This is a valid assumption. However, with many of the issues and problems encountered, answers will not be found in a ‘‘Howto’’ book or an employee manual. In the 10 years that our organization has operated in the Middle East, officials have come across a myriad of such concerns. As a result, we have acquired an insight into the not-so-obvious stumbling blocks that will arise and we want to share our experiences with safety professionals new to working abroad.
DUTY OF CARE
The goal of this article is to emphasize the need to be flexible, adaptable, and willing to go beyond what is normally expected in order to get the job done. This is particularly true with regards to occupational safety and setting up a safety program overseas. The
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
definition of occupational safety for a foreign operation cannot be constrained to only the safety of the workplace. In a foreign locale it is essential that the definition is expanded and best defined through the more broad term, Duty of Care. While not often discussed, occupational safety is a function of Duty of Care and it is important to note that all safety professionals labor to meet Duty of Care obligations as a part of their scope of work. Lisbeth defines Duty of Care as a legal concept that presumes ‘‘individuals and organizations have legal obligations to act toward others and the public in a prudent and cautious manner to avoid the risk of reasonably foreseeable injury to others.’’1 Duty of Care is about protecting stakeholders. It involves planning for and anticipating risk before events can occur. It does not mean that risks will become reality; rather it acknowledges that risks exist and that due diligence requires officials to identify reasonable foreseeable risks and mitigate them. Duty of Care is the backbone of safety management in that protecting stakeholders is the number one priority with regulatory compliance coming in at a close second. When working in your home country, safety management generally applies to the occupational safety environment with little or no obligation to protect employees when off the clock. In a foreign environment, safety
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[(Figure_1)TD$IG] takes on a larger, more comprehensive meaning as employers are obligated to ensure a degree of protection is afforded to expatriate employees and their dependents that are living in country. In an international setting, due to Duty of Care requirements, safety programs extend their coverage to 24/7 at work, home, and business travel for international assignees, dependents of international assignees, and official visitors to the foreign operation. In addition, it requires safety professionals to broaden their scope beyond occupational safety to include building and fire codes, emergency response, crisis management and security management. For example, responsibilities in a foreign safety program often extend beyond basic fire code safety within the work location to include the development and implementation of comprehensive fire safety, construction compliance, and security plans for residential locations. Hazardous material management can extend beyond storage and use in the work place to auditing vendors for safe practices and providing documentation to clear customs. The HSSE (Health, Safety, Security, and Environment) department at our Middle East branch campus not only manages hazardous materials, but also works with government officials on importing chemicals into the country in compliance with ever-fluctuating and sometimes vague local laws.
UNIVERSITY – FACTS AND FIGURES
Our branch campus started with only eight people on the ground in the Middle East, 10 years ago. Since then, with the help of our sponsoring organization, the branch campus has grown into a teaching and research leader in the region. Offering degrees in four engineering disciplines, the branch campus currently hosts approximately 450 undergraduate students, 30 graduate students in the new chemical engineering Master’s program, 60 research faculty, 180 full-time postdoctoral and research scientists and manages $85 million dollars of research funding spread across 120 projects with collaborations around the world
Figure 1. Texas A&M University at Qatar Building.
(Figure 1). This growth has been extremely fast with severe growing pains. The HSSE program was not created until six years ago. Setting up shop in a foreign locale is intense. Initial focus, as one would imagine, is on setting up and maintaining basic services. Assessing and mitigating risk at this point is a luxury and often put on the backburner for that elusive day when you have time to look into what might happen instead of dealing with what is happening. Needless to say, bringing safety and security into the equation four years into the operation added to the complicated process of compliance, as catching up on existing practices while simultaneously planning for future needs became the operational norm for the safety officer hired to build the HSSE program. The lesson learned is that organizations looking at setting up operations overseas should engage a safety and security professional at the very beginning of the discussion and ensure safety and security is considered at each stage of development in order to ensure that all aspects of Duty of Care are acknowledged including the identification of key stakeholders and responsibilities toward them. The importance of assessing all risk to stakeholders and developing a risk management plan before operations begin should not be underestimated or ignored.
FACILITIES
The sponsoring organization that brought our university to the region
Journal of Chemical Health & Safety, September/October 2013
has provided architecturally innovative facilities to house our faculty and staff. The completion of the engineering building created for our branch campus represents a team effort between the University and the sponsoring foundation during the design and construction phase. However, the input from University leaders focused mainly on academic requirements with only nominal input toward research laboratories and other future research needs. As a result, research laboratories were built in the exact same layout, consisting of three to four hoods, modular benches, gas systems for up to six different gases, ducted gas cabinets for oxygen and hydrogen, and limited power supply, network ports, and gas outlets (Figure 2). Anyone familiar with engineering research will recognize that ‘‘one size fits all’’ is not an optimum layout for engineering research space. While the laboratories have all of the modern amenities, this ‘‘one size fits all’’ design approach has caused many challenges due to the wide range of equipment and research interests housed within. All of the laboratories were designed for low to moderate hazards thus requiring modifications for research associated with higher risk. Laser and NMR enclosures were not considered as a part of the original design thus needed to be built into lab spaces after the fact. In addition, future expansion is severely limited and moving forward with required renovation is neither easy nor quick, as the branch campus sponsor requires that any building or room modification get 3
[(Figure_2)TD$IG]
Figure 2. Standard Research Lab.
approval from the design architects for style and aesthetics. This makes any external modifications impossible and internal modifications extremely difficult to undertake. The lesson learned here is to become involved with all aspects of design and construction and remain involved to ensure space meets current and future needs of your operation. Another complication that arises with facility, equipment, and instrument maintenance is the availability of spare parts and qualified technicians. It is extremely important to verify that upon purchasing equipment, the manufacturer has localized and/ or a regional infrastructure in place for service and maintenance. Service contracts should be established and must be budgeted for. In the case to highly specialized equipment such as an NMR, it may be necessary to fly authorized technicians in from abroad for service and maintenance at the expense of the purchaser. Some of these more routine service expenses can be avoided by ensuring that organization employees have received training and are experienced in troubleshooting advanced instrumentation. When possible, spare consumables should be kept on hand as this can greatly lessen instrumental downtime and the international ordering and shipping process can be avoided. If the facility is maintained by the foreign entity as the sponsoring organization, it is important to maintain a robust relationship with their facilities and maintenance departments. 4
Schedule regular meetings and develop organizational liaisons to ensure that repairs are made in a timely fashion and necessary spare parts that could shut down operations are kept on hand. It may be necessary to vet contractors and maintenance personal to ensure competence if they are being brought in locally as a third party.
PHYSICAL SECURITY AND EXPORT CONTROL CHALLENGES
In the Middle East, we are very aware of the potential security challenges the branch campus faces. Security issues exist on several levels, from regional political issues down to campus and local building security. Again, assessing security risk before operations begin is essential but risk assessment with regards to security must not end at initial assessment. It is an on-going process and assessment must include the country of operation as well as the entire region and other locations to which the employees will be traveling as a part of their job responsibilities. In this regard, a robust security program is needed to continually identify and mitigate predictable as well as uncertain risk and includes risk associated with the work place, employee residences, visitor hotels, and all business travel. Risk associated with employees is given but it is also important to manage risk associated with visitors to the foreign operation. When working aboard, spontaneous VIP visits are common. While all visitors are required to give
IDs, local security are often hesitant to stop high profile Nationals and heads of state at the door thus creating the potential for persons accessing your facility who have not been properly vetted. The breach in physical security is obvious under these circumstances, but for an educational facility undertaking a significant amount of research, a less common security issue comes to the forefront: export control. The U.S. Government controls the export of sensitive equipment, software and technology as a matter of national security. The requirements associated with this initiative are a critical issue for all U.S. universities. However, U.S. universities operating abroad, as one would expect, have additional complexities to manage. Not so surprisingly, equipment and intellectual property exported from the U.S. must be evaluated with regards to export control requirements. What also must be acknowledged is that U.S universities operating abroad must evaluate export control requirements with respect to equipment and intellectual property used and created at the foreign locale. All items subject to export control must conform to Export Administration Regulations (EAR) and International Traffic in Arms (ITAR) regulations. Anyone who has access to the equipment or information must be vetted based upon their nationality and background. All new employees or students must undergo an export control background check before access to certain areas and items are granted. Even visitors to the university must be screened before given access. To ensure the university follows all export control guidelines, any equipment on an official export control lists is tagged and locked down using door locks and computer passwords to maintain a security barrier. No photography is allowed in areas where controlled items or information are stored and all control requirements must be documented. The lesson learned is that security issues extend beyond what is normally encountered in operations at home. Assessment, in conjunction with organizational risk and liability officials, must occur to identify all security risks
Journal of Chemical Health & Safety, September/October 2013
with steps taken early to mitigate and manage those risks.
HAZARDOUS MATERIALS
One of the fundamental aspects of running research operations is the ability to procure hazardous materials. Whether it is chemicals, compressed gases, or instrumentation; all pose unique challenges that a university setting up operations in a foreign country may not anticipate. Due to the complications involved in this process, the branch campus HSSE office oversees all aspects of the hazardous materials process from the procurement to the disposal. Department members maintain International Air Transport Association Dangerous Goods (IATA) certifications. They pursue quotations from various vendors, identify potential import/export issues, and handle various licensing issues from both the export country and the local authorities. The timelines for hazardous materials can also be a very unique challenge that people are not used to facing on their home campuses. For our branch campus, there are no means for ground transportation of materials purchased outside of the country, so all HAZMAT has to be shipped via air or sea and must cross international borders. A typical chemical shipment sent by air takes six to eight weeks from the time a lab employee requisitions it to the time it arrives. Adding to the time delay are the specific purchasing requirements mandated by our parent institution. As a State institution, we must follow all purchasing requirements promulgated by State legislators. Equipment and chemical orders over a specified dollar amount must go out for multiple bids adding to the time delay. Further complicating the process is the fact that extremely hazardous or bulk items must be shipped by sea, with delivery often taking six months to one year. This timeline comes as quite a shock to researchers that are used to receiving items via ground transport in seventy-two hours. In an effort to expedite shipping, the HSSE office has worked closely with
exporting vendors to create the appropriate paperwork and chains-of-custody in advance of delivery to hasten approvals needed from local ministries to import hazardous materials. The lesson learned is that organizations setting up operations abroad must begin working, as soon as possible, with local governments and vendors to set up supply chain agreements to be able to meet operational needs when the time comes. Cost is also a huge consideration that is not accounted for by researchers moving operations abroad. Chemicals can cost more than double what they would cost at institutions located in the U.S. Not only are the chemical prices higher than what is seen at home, additional fees equaling 20– 100% can be added to already inflated prices for shipping and documentation. An extreme case for our branch campus involved five grams of a chemical with a price tag of $500 that ended up costing the researcher in excess of $3000 due to shipping constraints placed on the material due to its reactivity. The lesson learned is that research operations must inform Principle Investigators (PI) about cost and supply constraints before research is accepted. Transparency prior to research start-up is essential in managing PI expectations and also allows the PI to plan accordingly when budgeting research funds for purchasing. Hazardous waste disposal can also pose challenges when opening an operation abroad. Because regulations and waste disposal infrastructure can vary widely by country, it is impor[(Figure_3)TD$IG]tant to meet with the appropriate
government entities during the planning stages of the operations. One must learn the local laws and regulations, identify safe and prudent disposal methods, and identify potential hazardous waste vendors. Depending on the availability of waste disposal vendors, it may be prudent to limit the types of research that the facility can perform and to appropriately modify teaching labs to eliminate certain waste streams.
REGULATORY REQUIREMENTS ARE NOT GLOBALLY UNIFORM
Often in foreign locales, the different agencies that regulate fire, chemical, and building safety rarely follow a common set of safety codes or regulations, and have very little communication between them. It is important to note not all countries have codified regulations pertaining to safety requirements. As a result, different local inspectors may utilize safety requirements taken from various international bodies regarding safety practices that directly contradict each other; yet each inspector has the legal authority to impose their regulations. Adding to the complexity is the requirement that many overseas operations are obligated to comply with the foreign standards in the country of operation as well as regulatory standards required at home. The lesson learned is foreign operations must initiate conversations with government officials in their country of operation early to understand foreign requirements, explain U.S. requirements that must
Figure 3. Chemical storage room for Chemistry Department.
Journal of Chemical Health & Safety, September/October 2013
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be adhered to and develop a relationship that will allow for discrepancies and challenges to be addressed in a timely fashion and in a manner that meets compliance requirements for all involved (Figure 3).
LABORATORY SAFETY AND CULTURAL NORMS
Working abroad requires an understanding of the local cultural and social norms and issues. In the Middle East, culture and religion are often interwoven and this social norm must be acknowledged and respected while maintaining the required standards for safety. For students, this requires more than just training. Conversations revolving around the history of safety requirements, as well as the relevance of such requirements to student safety is needed in order to gain buy-in as well as trust. In addition, rules must be explained and enforced in a way that is not offensive to the culture. For instance, in most of the Middle East, it is extremely rude for a man or woman to touch in any way unless they are related or married, and men and women generally maintain a comfortable distance between themselves at all times. This practice is routinely followed without incidence, but during safety training the University must convey the importance of an instructor’s need to hold someone’s eyes open at an eye wash station, or the removal of clothing under a safety shower in case of a chemical spill on the body. By explaining that their safety and well being is the University’s primary concern, the social stigma that may develop during an emergency can be eliminated. Further minimizing these moments of social awkwardness is possible by keeping handy phone numbers of staff of the opposite sex available during lab sessions to assist during a crisis, keeping large lab coats available for privacy during emergency disrobing and asking members of the opposite sex to leave the area during moments of modesty. Another such cultural issue is a person’s manner of dress. In the Middle East, most men wear a variation of the thobe, a floor-length robe, the gutra
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with agal, which are the traditional headdress with braided cord, and open-toed sandals. For the women, they wear a variation of the abaya, a floor-length robe with the shayla, or long headscarf that wraps around the individuals hair. Some women also wear the niqab, a type of face veil that conceals the entire face except for the eyes. As HSSE professionals, it is important to maintain laboratory safety standards without ignoring the cultural tenets. Therefore, the University asks the men to remove their gutras and agals so that the long cords and flowing headdresses cannot interfere with chemicals or equipment. For the women, as the uncovered head is culturally unacceptable, the University requires that the scarf be tucked into the abaya so that it does not dangle. For women wearing the face veil, a flame-resistant surgical mask is worn while the individual is in the lab. This way the women can maintain their modesty and cover the face, but minimize any flammability or snagging risks. All students are required to wear splash resistant lab coats, safety glasses/goggles and closed-toed shoes at all times during laboratory operations. The lesson learned is take time to learn and understand cultural norms and customs and do not underestimate their significance with regards to your operations.
TRAINING PROGRAMS
For foreign operations, safety and security training must extend beyond persons directly involved with the overseas operations. In this regard, training must also include employee dependents as the well as visitors traveling on official business. In many cases, training may extend to external stakeholders such as vendors, transporters, and other auxiliary roles vital to the operation. Training must be developed that acknowledges cultural differences on many different levels and embraces the differences in a way that reinforces the overall safety program. Appreciating that the perception of what is considered safe differs amongst diverse cultures is vital to effective training. To alleviate these
differences, the HSSE office makes an effort to invite health and safety personnel from the local government ministries as well as local vendors to attend branch campus training sessions. External stakeholders have joined our employees in HAZWOPER, IATA, and international chemical security training to the benefit of all involved. With regards to what is considered safe between diverse nationalities, the HSSE office become aware of a serious liability that exists within the labor class hired to perform manual work within the branch campus facilities. Laborers, generally relocated to the Middle East from Asia, are hired to perform work by third party contractors and are often put in the work environment with little or no safety training. In this regard, the HSSE personnel witnessed these workers exhibiting unsafe practices of a nature that is not seen in operations at home because of inherent perception of risk that exists within Western culture. Examples of unsafe practices discovered and stopped include janitors wading into raw sewage with bare feet during a plumbing disaster, window washers hoisting ladders onto three story ledges and delivery drivers rolling flammable cylinders down hallways. A serious problem arose when the branch campus started to receive hazardous chemicals and equipment from untrained customs-to-loading dock shippers. At the branch campus loading dock, employees witnessed uncapped flammable cylinders rolling unrestrained in the back of a truck. A vendor once delivered to the branch campus bottles of sulfuric acid, not in protective boxes with leak protection material, but haphazardly thrown into the backseat of a small car; bottles falling onto the floor and rolling under the driver’s seat. To stop the rampant unsafe practices of these laborers, the HSSE office requires all vendors and laborers working in building or delivering to the building to follow prescribed health and safety rules and regulations, with the onus on the laborer supervisors to ensure that safe practices be maintained at all times. The branch campus has also negotiated proper
Journal of Chemical Health & Safety, September/October 2013
[(Figure_5)TD$IG]
[(Figure_4)TD$IG]
Figure 4. HAZWOPER Training.
Figure 5. Seconded janitorial staff cleaning a laboratory while wearing PPE and after proper training.
safety equipment be used and proper procedures be followed by all local vendors doing business with it. In addition, a trained security guard is posted on the loading dock to ensure shipments coming into the branch campus are compliant or the shipment is held until the vendor is contacted and the hazardous materials are rendered safe for movement. The lesson learned is the recognition that any person or group that has access to the organization can negatively impact operations. Training to offset this impact can be incredibly beneficial to the organization especially when training is designed to acknowledge that diverse nationalities may perceive acceptable safety measures differently (Figures 4 and 5).
SAFETY BEYOND THE UNIVERSITY
As previously stated, Duty of Care is about protecting stakeholders far
beyond when they are within operational facilities; it also extends to their residences within the country of operation as well as business travel outside of the country of operation. An example that illustrates the importance of 24/7 Duty of Care requirements involves a fire that broke out in a high-rise residential tower in 2009. The high-rise apartment building in question housed many branch campus employees and their families. When notified of the fire, HSSE officials activated the Emergency Calling Program to contact employees in the building to provide direction on where to rendezvous upon exiting the building and to learn of alternate accommodations being made to house displaced families. Imagine the surprise of emergency callers when they learned that many employees were not aware that the building was on fire because no fire alarms could be heard within their apartments. Thankfully, there were no injuries or fatalities. However, this
Journal of Chemical Health & Safety, September/October 2013
near tragedy prompted HSSE to undergo an extensive review of the fire and safety protocols of the apartment building in question. After a basic inspection, HSSE discovered disconnected fire alarms, blocked emergency exits, and entire sprinkler systems that were not connected to a water supply. The failure by building managers to recognize these serious hazards prompted the HSSE office to overhaul the entire residential leasing process. HSSE safety staff participated in building and construction safety inspection training, and all housing units leased for employees by the branch campus underwent fire safety and security audits. Any units not meeting basic safety standards were removed from the employee housing plan. All housing units must now demonstrate their fire and emergency safety plans on an annual basis. In addition, private security firms that assist in inspection as well as property management have been retained to support the process of acquiring safe and reliable housing for branch campus employees and their families. The lesson learned is that when it comes to reliance upon established construction and fire code standards, assume nothing. Due diligence is not only smart in these instances; it is essential. Establish a program that involves a thorough review of safety programs and practices utilized at hotels and private residences obtained by your organization for use by employees and visitors.
CRISIS PREPAREDNESS AND HAZARD MITIGATION
Duty of Care from a crisis preparedness standpoint involves three main provisions: educating travelers and assignees about the risks in the area where they will be working or visiting, monitoring the environment for potential hazards and updating travelers as needed, and adequately supporting and assisting travelers and assignees in the event of a crisis or emergency. To accomplish these goals, the organization operating abroad must understand what can and will go wrong in an international setting. A crisis preparedness and hazard mitigation plan
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[(Figure_6)TD$IG] (CPHM Plan) must be developed. This plan should assign planning responsibility for an international crisis to a responsible and qualified individual. Communication between international operations and home locations must be established and available in time of a crisis. Hazard assessments for locales where you operate and for the operations undertaken should be performed and communicated to the assignees abroad. This includes not only permanent foreign operations but intermittent travel to foreign locales as well. Tracking travel of employees in relationship to security issues that are developing while the employee is traveling is a full-time job. For organizations that cannot dedicate an individual or individuals to tracking travel and monitoring global security issues, retaining the services of a vendor specializing in this service is a must. Professional security services have the experience and the knowhow to provide a wide variety of assistance from travel tracking and regional security monitoring to security extractions and medical evacuations from foreign destinations when needed. An effective plan must also include training for visitors and expatriates to ensure they are personally prepared for crisis should it occur. Members of your organizations should be informed about the importance of keeping copies of important documents, having adequate supply of prescription medications on hand as well as a supply of cash for emergencies. In addition, being prepared for sheltering-in-place is also important thus advising employees and their families to have an adequate supply of food and water available should shelter-in-place be required is a critical component of the CHMP. Once a CPHM plan is in place, an all-hazards risk assessment review is required. Security consultants can assist with this type of assessment as can sponsoring organizations, hotel manager, and housing managers, but the responsibility lies upon the employer to ensure that the risks are fully understood and mitigated to the greatest degree possible. While HSSE officials routinely assess potential risk, 8
Figure 6. Example of a Crisis Preparedness Kit.
they must broaden their scope to areas not commonly thought of when operating internationally. In case of emergency medical care, most risk assessment would stop as soon as the injured reached medical care. But overseas, the quality and availability of medical care must be questioned with limitations on the care to be provided understood. The same applies for police, fire, and ambulatory care and response. When limitations are identified, strategy must be developed that mitigates these limitations up to and including medical evacuation to a qualified care facility when needed. The lesson learned is that significant problems can occur anywhere, at any time, and escalate quickly into fullfledged crises overnight. Therefore, travelers and expatriates must be educated and be made aware of potential risks and told the importance of self preparation in order to be the most resilient in the face of crisis. At our branch campus, we have several programs in place that allow for employee accountability as well as promote individual preparedness. Included in these practices are travel-tracking provisions in which all employees/families must register their travel outside of the country of operation. This must occur before travel can be approved and includes all aspects of the traveler’s itinerary as well as emergency contact information. The same process occurs for any official visitors, dependents of employees, or students traveling to our branch campus. Travelers and relocators must be made aware of any potential dangers or risks they may encounter in the areas they are visiting,
using updates from the U.S. Department of State and private security firms. Foreign locales are constantly monitored by intelligence analysts for potential hazards that develop during the time of travel. These updates include political unrest, medical outbreaks, and breaking security information. In addition, the HSSE provides shelter-in-place kits to all employees of the branch campus to aid in individual preparation. Employees are trained in the content and use of the kit with routine verification from the employee that kits are still present in the home and adequately stocked (Figure 6).
EMERGENCY COMMUNICATION: THE BACKBONE OF CRISIS MANAGEMENT
Another factor not routinely scrutinized is communication capability in the region of travel or operation. The Arab spring that resulted in significant unrest in many areas of the Middle East highlights the importance of this issue as many travelers and international employees were left without a means to communicate as governmental regimes deliberately shutdown landline/mobile phone and Internet access. In this regard, it is important to note that when a crisis occurs, getting people out of harm’s way is the first priority. Communicating efficiently is critical to accomplishing this task and is the backbone of a well-designed preparedness plan. Therefore having an effective communication plan is
Journal of Chemical Health & Safety, September/October 2013
essential. Your crisis team should be able to communicate in a variety of ways, including: landlines, mobile phones, robo-calling, SMS, email, websites, calling bridges, satellite phones, and even going door-to-door or what some people call ‘‘sneaker net.’’ If the local government can shut down phone and Internet communications during a crisis, how would you communicate vital information to your people scattered across a large city? Or what of those people traveling abroad? The lesson learned is that an internal and external communication strategy must be created to handle different levels of emergencies with consideration for the different types of communication technology that may or may not be available at the time of crisis. Requiring a 24/7-communication line through a third party is a very useful strategy. A system where a dedicated employee is ‘‘on-call’’ is useful, yet simple misfires such as turning a ringer
off or not charging a phone can result is serious consequences if someone is in dire need. Hence the recommendation that a manned hotline be contracted through a firm that will guarantee all phone calls will be answered.
CONCLUSIONS
To conclude, safety and security responsibilities for foreign operations can be convoluted and complex. As a result, it is important that organizations considering expanding their operations to foreign locales ensure that safety and security considerations are included at the beginning, middle and end of each foreign venture and these important programs incorporate the inflated definition of Duty of Care. The first step in this process is acknowledging the increase in risk and support whole-heartedly the development of a robust program to
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mitigate the risk. This requires dedicating adequate resources to program including the allocation of an adequate budget. The second step is hiring an experienced safety and security professional that is flexible enough to recognize and accept that rules and requirements in place at home may not exist or be enforceable abroad yet is still capable of mitigating foreseeable risk. Finally, the organization must be willing to redefine accepted best practices by augmenting what is accepted as compliant with creative solutions that manage risk to the greatest extent possible in order to realize the most benefit from the new adventures of operating abroad. REFERENCE 1. Lisbeth, C. Duty of Care of Employers for Protecting International Assignees, their Dependents, and International Business Travelers. Int. SOS White Paper Ser. 2011, 8.
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Challenges and insights of creating a safety program abroad Establishing business and academic endeavors abroad is an exciting and extremely challenging undertaking. This is especially true when setting up ventures that have the complications of an academic institution complete with world-class research laboratories and a diversified faculty, staff and student population from over 50 countries. This article will take the readers through many of the challenges associated with setting up an institution abroad from the start-up to the fully operational phases. The authors will examine an expanded view on ‘‘Duty of Care’’, security challenges, hazardous material experiences, cultural challenges, and crisis preparedness programs; all while giving a first hand account of tackling these different issues far removed from the parent campus.
By Marne Smith, Brandon S. Chance, G. Benjamin Cieslinski INTRODUCTION
Every year businesses and academic enterprises branch out and expand into the farthest regions of the world. For the officials and managers tasked with setting up this type of endeavor it can be exciting, motivating, and energizing as you dive into the local culture and cuisine. But it can also be convoluted, complicated, and frustrating as Marne Smith, M.Sc., CHMM, CET is the Director of the Office of Building Operations and HSSE, Texas A&M University at Qatar, PO Box 23874, Doha, Qatar (e-mail: [email protected]). Brandon S. Chance, M.S., CCHO is the Chemical Safety Program Manager with the Office of Environmental Health and Safety, Princeton University, 262 Alexander Street, Princeton, NJ 08540, United States (Tel.: +1 6099551289; e-mail: [email protected]). G. Benjamin Cieslinski is the Laboratory Manager with the Department of Science, Texas A&M University at Qatar, PO Box 23874, Doha, Qatar (e-mail: benjamin.cieslinski@qatar. tamu.edu).
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you attempt to navigate unfamiliar waters of foreign concepts of responsibility and legal quagmires. Successful managers of foreign ventures must have an in-depth understanding of not just the culture in which they will operate, but also an understanding of the complexities and problems that will arise as a result of operating in a foreign locale. One can assume that working in a foreign locale will require learning the local laws and regulations to develop an effective operation. This is a valid assumption. However, with many of the issues and problems encountered, answers will not be found in a ‘‘Howto’’ book or an employee manual. In the 10 years that our organization has operated in the Middle East, officials have come across a myriad of such concerns. As a result, we have acquired an insight into the not-so-obvious stumbling blocks that will arise and we want to share our experiences with safety professionals new to working abroad.
DUTY OF CARE
The goal of this article is to emphasize the need to be flexible, adaptable, and willing to go beyond what is normally expected in order to get the job done. This is particularly true with regards to occupational safety and setting up a safety program overseas. The
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
definition of occupational safety for a foreign operation cannot be constrained to only the safety of the workplace. In a foreign locale it is essential that the definition is expanded and best defined through the more broad term, Duty of Care. While not often discussed, occupational safety is a function of Duty of Care and it is important to note that all safety professionals labor to meet Duty of Care obligations as a part of their scope of work. Lisbeth defines Duty of Care as a legal concept that presumes ‘‘individuals and organizations have legal obligations to act toward others and the public in a prudent and cautious manner to avoid the risk of reasonably foreseeable injury to others.’’1 Duty of Care is about protecting stakeholders. It involves planning for and anticipating risk before events can occur. It does not mean that risks will become reality; rather it acknowledges that risks exist and that due diligence requires officials to identify reasonable foreseeable risks and mitigate them. Duty of Care is the backbone of safety management in that protecting stakeholders is the number one priority with regulatory compliance coming in at a close second. When working in your home country, safety management generally applies to the occupational safety environment with little or no obligation to protect employees when off the clock. In a foreign environment, safety
1871-5532/$36.00 http://dx.doi.org/10.1016/j.jchas.2013.03.001
[(Figure_1)TD$IG] takes on a larger, more comprehensive meaning as employers are obligated to ensure a degree of protection is afforded to expatriate employees and their dependents that are living in country. In an international setting, due to Duty of Care requirements, safety programs extend their coverage to 24/7 at work, home, and business travel for international assignees, dependents of international assignees, and official visitors to the foreign operation. In addition, it requires safety professionals to broaden their scope beyond occupational safety to include building and fire codes, emergency response, crisis management and security management. For example, responsibilities in a foreign safety program often extend beyond basic fire code safety within the work location to include the development and implementation of comprehensive fire safety, construction compliance, and security plans for residential locations. Hazardous material management can extend beyond storage and use in the work place to auditing vendors for safe practices and providing documentation to clear customs. The HSSE (Health, Safety, Security, and Environment) department at our Middle East branch campus not only manages hazardous materials, but also works with government officials on importing chemicals into the country in compliance with ever-fluctuating and sometimes vague local laws.
UNIVERSITY – FACTS AND FIGURES
Our branch campus started with only eight people on the ground in the Middle East, 10 years ago. Since then, with the help of our sponsoring organization, the branch campus has grown into a teaching and research leader in the region. Offering degrees in four engineering disciplines, the branch campus currently hosts approximately 450 undergraduate students, 30 graduate students in the new chemical engineering Master’s program, 60 research faculty, 180 full-time postdoctoral and research scientists and manages $85 million dollars of research funding spread across 120 projects with collaborations around the world
Figure 1. Texas A&M University at Qatar Building.
(Figure 1). This growth has been extremely fast with severe growing pains. The HSSE program was not created until six years ago. Setting up shop in a foreign locale is intense. Initial focus, as one would imagine, is on setting up and maintaining basic services. Assessing and mitigating risk at this point is a luxury and often put on the backburner for that elusive day when you have time to look into what might happen instead of dealing with what is happening. Needless to say, bringing safety and security into the equation four years into the operation added to the complicated process of compliance, as catching up on existing practices while simultaneously planning for future needs became the operational norm for the safety officer hired to build the HSSE program. The lesson learned is that organizations looking at setting up operations overseas should engage a safety and security professional at the very beginning of the discussion and ensure safety and security is considered at each stage of development in order to ensure that all aspects of Duty of Care are acknowledged including the identification of key stakeholders and responsibilities toward them. The importance of assessing all risk to stakeholders and developing a risk management plan before operations begin should not be underestimated or ignored.
FACILITIES
The sponsoring organization that brought our university to the region
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has provided architecturally innovative facilities to house our faculty and staff. The completion of the engineering building created for our branch campus represents a team effort between the University and the sponsoring foundation during the design and construction phase. However, the input from University leaders focused mainly on academic requirements with only nominal input toward research laboratories and other future research needs. As a result, research laboratories were built in the exact same layout, consisting of three to four hoods, modular benches, gas systems for up to six different gases, ducted gas cabinets for oxygen and hydrogen, and limited power supply, network ports, and gas outlets (Figure 2). Anyone familiar with engineering research will recognize that ‘‘one size fits all’’ is not an optimum layout for engineering research space. While the laboratories have all of the modern amenities, this ‘‘one size fits all’’ design approach has caused many challenges due to the wide range of equipment and research interests housed within. All of the laboratories were designed for low to moderate hazards thus requiring modifications for research associated with higher risk. Laser and NMR enclosures were not considered as a part of the original design thus needed to be built into lab spaces after the fact. In addition, future expansion is severely limited and moving forward with required renovation is neither easy nor quick, as the branch campus sponsor requires that any building or room modification get 3
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Figure 2. Standard Research Lab.
approval from the design architects for style and aesthetics. This makes any external modifications impossible and internal modifications extremely difficult to undertake. The lesson learned here is to become involved with all aspects of design and construction and remain involved to ensure space meets current and future needs of your operation. Another complication that arises with facility, equipment, and instrument maintenance is the availability of spare parts and qualified technicians. It is extremely important to verify that upon purchasing equipment, the manufacturer has localized and/ or a regional infrastructure in place for service and maintenance. Service contracts should be established and must be budgeted for. In the case to highly specialized equipment such as an NMR, it may be necessary to fly authorized technicians in from abroad for service and maintenance at the expense of the purchaser. Some of these more routine service expenses can be avoided by ensuring that organization employees have received training and are experienced in troubleshooting advanced instrumentation. When possible, spare consumables should be kept on hand as this can greatly lessen instrumental downtime and the international ordering and shipping process can be avoided. If the facility is maintained by the foreign entity as the sponsoring organization, it is important to maintain a robust relationship with their facilities and maintenance departments. 4
Schedule regular meetings and develop organizational liaisons to ensure that repairs are made in a timely fashion and necessary spare parts that could shut down operations are kept on hand. It may be necessary to vet contractors and maintenance personal to ensure competence if they are being brought in locally as a third party.
PHYSICAL SECURITY AND EXPORT CONTROL CHALLENGES
In the Middle East, we are very aware of the potential security challenges the branch campus faces. Security issues exist on several levels, from regional political issues down to campus and local building security. Again, assessing security risk before operations begin is essential but risk assessment with regards to security must not end at initial assessment. It is an on-going process and assessment must include the country of operation as well as the entire region and other locations to which the employees will be traveling as a part of their job responsibilities. In this regard, a robust security program is needed to continually identify and mitigate predictable as well as uncertain risk and includes risk associated with the work place, employee residences, visitor hotels, and all business travel. Risk associated with employees is given but it is also important to manage risk associated with visitors to the foreign operation. When working aboard, spontaneous VIP visits are common. While all visitors are required to give
IDs, local security are often hesitant to stop high profile Nationals and heads of state at the door thus creating the potential for persons accessing your facility who have not been properly vetted. The breach in physical security is obvious under these circumstances, but for an educational facility undertaking a significant amount of research, a less common security issue comes to the forefront: export control. The U.S. Government controls the export of sensitive equipment, software and technology as a matter of national security. The requirements associated with this initiative are a critical issue for all U.S. universities. However, U.S. universities operating abroad, as one would expect, have additional complexities to manage. Not so surprisingly, equipment and intellectual property exported from the U.S. must be evaluated with regards to export control requirements. What also must be acknowledged is that U.S universities operating abroad must evaluate export control requirements with respect to equipment and intellectual property used and created at the foreign locale. All items subject to export control must conform to Export Administration Regulations (EAR) and International Traffic in Arms (ITAR) regulations. Anyone who has access to the equipment or information must be vetted based upon their nationality and background. All new employees or students must undergo an export control background check before access to certain areas and items are granted. Even visitors to the university must be screened before given access. To ensure the university follows all export control guidelines, any equipment on an official export control lists is tagged and locked down using door locks and computer passwords to maintain a security barrier. No photography is allowed in areas where controlled items or information are stored and all control requirements must be documented. The lesson learned is that security issues extend beyond what is normally encountered in operations at home. Assessment, in conjunction with organizational risk and liability officials, must occur to identify all security risks
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with steps taken early to mitigate and manage those risks.
HAZARDOUS MATERIALS
One of the fundamental aspects of running research operations is the ability to procure hazardous materials. Whether it is chemicals, compressed gases, or instrumentation; all pose unique challenges that a university setting up operations in a foreign country may not anticipate. Due to the complications involved in this process, the branch campus HSSE office oversees all aspects of the hazardous materials process from the procurement to the disposal. Department members maintain International Air Transport Association Dangerous Goods (IATA) certifications. They pursue quotations from various vendors, identify potential import/export issues, and handle various licensing issues from both the export country and the local authorities. The timelines for hazardous materials can also be a very unique challenge that people are not used to facing on their home campuses. For our branch campus, there are no means for ground transportation of materials purchased outside of the country, so all HAZMAT has to be shipped via air or sea and must cross international borders. A typical chemical shipment sent by air takes six to eight weeks from the time a lab employee requisitions it to the time it arrives. Adding to the time delay are the specific purchasing requirements mandated by our parent institution. As a State institution, we must follow all purchasing requirements promulgated by State legislators. Equipment and chemical orders over a specified dollar amount must go out for multiple bids adding to the time delay. Further complicating the process is the fact that extremely hazardous or bulk items must be shipped by sea, with delivery often taking six months to one year. This timeline comes as quite a shock to researchers that are used to receiving items via ground transport in seventy-two hours. In an effort to expedite shipping, the HSSE office has worked closely with
exporting vendors to create the appropriate paperwork and chains-of-custody in advance of delivery to hasten approvals needed from local ministries to import hazardous materials. The lesson learned is that organizations setting up operations abroad must begin working, as soon as possible, with local governments and vendors to set up supply chain agreements to be able to meet operational needs when the time comes. Cost is also a huge consideration that is not accounted for by researchers moving operations abroad. Chemicals can cost more than double what they would cost at institutions located in the U.S. Not only are the chemical prices higher than what is seen at home, additional fees equaling 20– 100% can be added to already inflated prices for shipping and documentation. An extreme case for our branch campus involved five grams of a chemical with a price tag of $500 that ended up costing the researcher in excess of $3000 due to shipping constraints placed on the material due to its reactivity. The lesson learned is that research operations must inform Principle Investigators (PI) about cost and supply constraints before research is accepted. Transparency prior to research start-up is essential in managing PI expectations and also allows the PI to plan accordingly when budgeting research funds for purchasing. Hazardous waste disposal can also pose challenges when opening an operation abroad. Because regulations and waste disposal infrastructure can vary widely by country, it is impor[(Figure_3)TD$IG]tant to meet with the appropriate
government entities during the planning stages of the operations. One must learn the local laws and regulations, identify safe and prudent disposal methods, and identify potential hazardous waste vendors. Depending on the availability of waste disposal vendors, it may be prudent to limit the types of research that the facility can perform and to appropriately modify teaching labs to eliminate certain waste streams.
REGULATORY REQUIREMENTS ARE NOT GLOBALLY UNIFORM
Often in foreign locales, the different agencies that regulate fire, chemical, and building safety rarely follow a common set of safety codes or regulations, and have very little communication between them. It is important to note not all countries have codified regulations pertaining to safety requirements. As a result, different local inspectors may utilize safety requirements taken from various international bodies regarding safety practices that directly contradict each other; yet each inspector has the legal authority to impose their regulations. Adding to the complexity is the requirement that many overseas operations are obligated to comply with the foreign standards in the country of operation as well as regulatory standards required at home. The lesson learned is foreign operations must initiate conversations with government officials in their country of operation early to understand foreign requirements, explain U.S. requirements that must
Figure 3. Chemical storage room for Chemistry Department.
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be adhered to and develop a relationship that will allow for discrepancies and challenges to be addressed in a timely fashion and in a manner that meets compliance requirements for all involved (Figure 3).
LABORATORY SAFETY AND CULTURAL NORMS
Working abroad requires an understanding of the local cultural and social norms and issues. In the Middle East, culture and religion are often interwoven and this social norm must be acknowledged and respected while maintaining the required standards for safety. For students, this requires more than just training. Conversations revolving around the history of safety requirements, as well as the relevance of such requirements to student safety is needed in order to gain buy-in as well as trust. In addition, rules must be explained and enforced in a way that is not offensive to the culture. For instance, in most of the Middle East, it is extremely rude for a man or woman to touch in any way unless they are related or married, and men and women generally maintain a comfortable distance between themselves at all times. This practice is routinely followed without incidence, but during safety training the University must convey the importance of an instructor’s need to hold someone’s eyes open at an eye wash station, or the removal of clothing under a safety shower in case of a chemical spill on the body. By explaining that their safety and well being is the University’s primary concern, the social stigma that may develop during an emergency can be eliminated. Further minimizing these moments of social awkwardness is possible by keeping handy phone numbers of staff of the opposite sex available during lab sessions to assist during a crisis, keeping large lab coats available for privacy during emergency disrobing and asking members of the opposite sex to leave the area during moments of modesty. Another such cultural issue is a person’s manner of dress. In the Middle East, most men wear a variation of the thobe, a floor-length robe, the gutra
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with agal, which are the traditional headdress with braided cord, and open-toed sandals. For the women, they wear a variation of the abaya, a floor-length robe with the shayla, or long headscarf that wraps around the individuals hair. Some women also wear the niqab, a type of face veil that conceals the entire face except for the eyes. As HSSE professionals, it is important to maintain laboratory safety standards without ignoring the cultural tenets. Therefore, the University asks the men to remove their gutras and agals so that the long cords and flowing headdresses cannot interfere with chemicals or equipment. For the women, as the uncovered head is culturally unacceptable, the University requires that the scarf be tucked into the abaya so that it does not dangle. For women wearing the face veil, a flame-resistant surgical mask is worn while the individual is in the lab. This way the women can maintain their modesty and cover the face, but minimize any flammability or snagging risks. All students are required to wear splash resistant lab coats, safety glasses/goggles and closed-toed shoes at all times during laboratory operations. The lesson learned is take time to learn and understand cultural norms and customs and do not underestimate their significance with regards to your operations.
TRAINING PROGRAMS
For foreign operations, safety and security training must extend beyond persons directly involved with the overseas operations. In this regard, training must also include employee dependents as the well as visitors traveling on official business. In many cases, training may extend to external stakeholders such as vendors, transporters, and other auxiliary roles vital to the operation. Training must be developed that acknowledges cultural differences on many different levels and embraces the differences in a way that reinforces the overall safety program. Appreciating that the perception of what is considered safe differs amongst diverse cultures is vital to effective training. To alleviate these
differences, the HSSE office makes an effort to invite health and safety personnel from the local government ministries as well as local vendors to attend branch campus training sessions. External stakeholders have joined our employees in HAZWOPER, IATA, and international chemical security training to the benefit of all involved. With regards to what is considered safe between diverse nationalities, the HSSE office become aware of a serious liability that exists within the labor class hired to perform manual work within the branch campus facilities. Laborers, generally relocated to the Middle East from Asia, are hired to perform work by third party contractors and are often put in the work environment with little or no safety training. In this regard, the HSSE personnel witnessed these workers exhibiting unsafe practices of a nature that is not seen in operations at home because of inherent perception of risk that exists within Western culture. Examples of unsafe practices discovered and stopped include janitors wading into raw sewage with bare feet during a plumbing disaster, window washers hoisting ladders onto three story ledges and delivery drivers rolling flammable cylinders down hallways. A serious problem arose when the branch campus started to receive hazardous chemicals and equipment from untrained customs-to-loading dock shippers. At the branch campus loading dock, employees witnessed uncapped flammable cylinders rolling unrestrained in the back of a truck. A vendor once delivered to the branch campus bottles of sulfuric acid, not in protective boxes with leak protection material, but haphazardly thrown into the backseat of a small car; bottles falling onto the floor and rolling under the driver’s seat. To stop the rampant unsafe practices of these laborers, the HSSE office requires all vendors and laborers working in building or delivering to the building to follow prescribed health and safety rules and regulations, with the onus on the laborer supervisors to ensure that safe practices be maintained at all times. The branch campus has also negotiated proper
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[(Figure_5)TD$IG]
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Figure 4. HAZWOPER Training.
Figure 5. Seconded janitorial staff cleaning a laboratory while wearing PPE and after proper training.
safety equipment be used and proper procedures be followed by all local vendors doing business with it. In addition, a trained security guard is posted on the loading dock to ensure shipments coming into the branch campus are compliant or the shipment is held until the vendor is contacted and the hazardous materials are rendered safe for movement. The lesson learned is the recognition that any person or group that has access to the organization can negatively impact operations. Training to offset this impact can be incredibly beneficial to the organization especially when training is designed to acknowledge that diverse nationalities may perceive acceptable safety measures differently (Figures 4 and 5).
SAFETY BEYOND THE UNIVERSITY
As previously stated, Duty of Care is about protecting stakeholders far
beyond when they are within operational facilities; it also extends to their residences within the country of operation as well as business travel outside of the country of operation. An example that illustrates the importance of 24/7 Duty of Care requirements involves a fire that broke out in a high-rise residential tower in 2009. The high-rise apartment building in question housed many branch campus employees and their families. When notified of the fire, HSSE officials activated the Emergency Calling Program to contact employees in the building to provide direction on where to rendezvous upon exiting the building and to learn of alternate accommodations being made to house displaced families. Imagine the surprise of emergency callers when they learned that many employees were not aware that the building was on fire because no fire alarms could be heard within their apartments. Thankfully, there were no injuries or fatalities. However, this
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near tragedy prompted HSSE to undergo an extensive review of the fire and safety protocols of the apartment building in question. After a basic inspection, HSSE discovered disconnected fire alarms, blocked emergency exits, and entire sprinkler systems that were not connected to a water supply. The failure by building managers to recognize these serious hazards prompted the HSSE office to overhaul the entire residential leasing process. HSSE safety staff participated in building and construction safety inspection training, and all housing units leased for employees by the branch campus underwent fire safety and security audits. Any units not meeting basic safety standards were removed from the employee housing plan. All housing units must now demonstrate their fire and emergency safety plans on an annual basis. In addition, private security firms that assist in inspection as well as property management have been retained to support the process of acquiring safe and reliable housing for branch campus employees and their families. The lesson learned is that when it comes to reliance upon established construction and fire code standards, assume nothing. Due diligence is not only smart in these instances; it is essential. Establish a program that involves a thorough review of safety programs and practices utilized at hotels and private residences obtained by your organization for use by employees and visitors.
CRISIS PREPAREDNESS AND HAZARD MITIGATION
Duty of Care from a crisis preparedness standpoint involves three main provisions: educating travelers and assignees about the risks in the area where they will be working or visiting, monitoring the environment for potential hazards and updating travelers as needed, and adequately supporting and assisting travelers and assignees in the event of a crisis or emergency. To accomplish these goals, the organization operating abroad must understand what can and will go wrong in an international setting. A crisis preparedness and hazard mitigation plan
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[(Figure_6)TD$IG] (CPHM Plan) must be developed. This plan should assign planning responsibility for an international crisis to a responsible and qualified individual. Communication between international operations and home locations must be established and available in time of a crisis. Hazard assessments for locales where you operate and for the operations undertaken should be performed and communicated to the assignees abroad. This includes not only permanent foreign operations but intermittent travel to foreign locales as well. Tracking travel of employees in relationship to security issues that are developing while the employee is traveling is a full-time job. For organizations that cannot dedicate an individual or individuals to tracking travel and monitoring global security issues, retaining the services of a vendor specializing in this service is a must. Professional security services have the experience and the knowhow to provide a wide variety of assistance from travel tracking and regional security monitoring to security extractions and medical evacuations from foreign destinations when needed. An effective plan must also include training for visitors and expatriates to ensure they are personally prepared for crisis should it occur. Members of your organizations should be informed about the importance of keeping copies of important documents, having adequate supply of prescription medications on hand as well as a supply of cash for emergencies. In addition, being prepared for sheltering-in-place is also important thus advising employees and their families to have an adequate supply of food and water available should shelter-in-place be required is a critical component of the CHMP. Once a CPHM plan is in place, an all-hazards risk assessment review is required. Security consultants can assist with this type of assessment as can sponsoring organizations, hotel manager, and housing managers, but the responsibility lies upon the employer to ensure that the risks are fully understood and mitigated to the greatest degree possible. While HSSE officials routinely assess potential risk, 8
Figure 6. Example of a Crisis Preparedness Kit.
they must broaden their scope to areas not commonly thought of when operating internationally. In case of emergency medical care, most risk assessment would stop as soon as the injured reached medical care. But overseas, the quality and availability of medical care must be questioned with limitations on the care to be provided understood. The same applies for police, fire, and ambulatory care and response. When limitations are identified, strategy must be developed that mitigates these limitations up to and including medical evacuation to a qualified care facility when needed. The lesson learned is that significant problems can occur anywhere, at any time, and escalate quickly into fullfledged crises overnight. Therefore, travelers and expatriates must be educated and be made aware of potential risks and told the importance of self preparation in order to be the most resilient in the face of crisis. At our branch campus, we have several programs in place that allow for employee accountability as well as promote individual preparedness. Included in these practices are travel-tracking provisions in which all employees/families must register their travel outside of the country of operation. This must occur before travel can be approved and includes all aspects of the traveler’s itinerary as well as emergency contact information. The same process occurs for any official visitors, dependents of employees, or students traveling to our branch campus. Travelers and relocators must be made aware of any potential dangers or risks they may encounter in the areas they are visiting,
using updates from the U.S. Department of State and private security firms. Foreign locales are constantly monitored by intelligence analysts for potential hazards that develop during the time of travel. These updates include political unrest, medical outbreaks, and breaking security information. In addition, the HSSE provides shelter-in-place kits to all employees of the branch campus to aid in individual preparation. Employees are trained in the content and use of the kit with routine verification from the employee that kits are still present in the home and adequately stocked (Figure 6).
EMERGENCY COMMUNICATION: THE BACKBONE OF CRISIS MANAGEMENT
Another factor not routinely scrutinized is communication capability in the region of travel or operation. The Arab spring that resulted in significant unrest in many areas of the Middle East highlights the importance of this issue as many travelers and international employees were left without a means to communicate as governmental regimes deliberately shutdown landline/mobile phone and Internet access. In this regard, it is important to note that when a crisis occurs, getting people out of harm’s way is the first priority. Communicating efficiently is critical to accomplishing this task and is the backbone of a well-designed preparedness plan. Therefore having an effective communication plan is
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essential. Your crisis team should be able to communicate in a variety of ways, including: landlines, mobile phones, robo-calling, SMS, email, websites, calling bridges, satellite phones, and even going door-to-door or what some people call ‘‘sneaker net.’’ If the local government can shut down phone and Internet communications during a crisis, how would you communicate vital information to your people scattered across a large city? Or what of those people traveling abroad? The lesson learned is that an internal and external communication strategy must be created to handle different levels of emergencies with consideration for the different types of communication technology that may or may not be available at the time of crisis. Requiring a 24/7-communication line through a third party is a very useful strategy. A system where a dedicated employee is ‘‘on-call’’ is useful, yet simple misfires such as turning a ringer
off or not charging a phone can result is serious consequences if someone is in dire need. Hence the recommendation that a manned hotline be contracted through a firm that will guarantee all phone calls will be answered.
CONCLUSIONS
To conclude, safety and security responsibilities for foreign operations can be convoluted and complex. As a result, it is important that organizations considering expanding their operations to foreign locales ensure that safety and security considerations are included at the beginning, middle and end of each foreign venture and these important programs incorporate the inflated definition of Duty of Care. The first step in this process is acknowledging the increase in risk and support whole-heartedly the development of a robust program to
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mitigate the risk. This requires dedicating adequate resources to program including the allocation of an adequate budget. The second step is hiring an experienced safety and security professional that is flexible enough to recognize and accept that rules and requirements in place at home may not exist or be enforceable abroad yet is still capable of mitigating foreseeable risk. Finally, the organization must be willing to redefine accepted best practices by augmenting what is accepted as compliant with creative solutions that manage risk to the greatest extent possible in order to realize the most benefit from the new adventures of operating abroad. REFERENCE 1. Lisbeth, C. Duty of Care of Employers for Protecting International Assignees, their Dependents, and International Business Travelers. Int. SOS White Paper Ser. 2011, 8.
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