Thermo Fisher Scientific is committed to protecting the environment, and the health and safety of our employees, customers and the communities where we operate. We hold ourselves responsible to the commitments made in our corporate-wide Environmental, Health and Safety (EHS) Policy and also implement a variety of robust systems and programs to ensure we meet its intent and expectations. All employees and senior business leaders are responsible for ensuring we meet our EHS Policy expectations.
EHS Management System ("EHS-MS") Policy
To help meet the commitments contained in our EHS Policy, we have also developed and are driving implementation of additional requirements contained and documented in our EHS Management System Policy. The EHS-MS Policy is comprised of a set of systems-based management expectations and processes that all manufacturing, distribution, and laboratory entities are required to abide by and implement. Our EHS-MS is based on the same tenets contained in a wide variety of existing and generally accepted EHS management system standards and practices (e.g., ISO 14001, OHSAS 18001, ISO 45001 and U.S. OSHA’s “Recommended Practices for Safety and Health Programs”), adapted and customized to integrate effectively into Thermo Fisher Scientific’s corporate governance structure and operating philosophy.
The EHS-MS Policy contains six (6) key elements. Each element contains multiple discrete requirements that must be met and maintained by individual operating entities and locations around the world.
- Management support and leadership – Requires a demonstrated management commitment to our EHS Policy, development of an effective EHS management culture at each location, establishment of relevant and measurable EHS related goals, development of a means to demonstrate goals are being achieved, and provision of adequate resources (and assigned roles and responsibilities) to implement an EHS-MS that achieves established goals and expectations.
- Employee participation – Requires employee participation in all phases of developing and implementing an effective EHS-MS and associated processes. This includes requirements for explicit employee involvement in (a) identifying EHS hazards and developing effective risk management strategies; (b) establishing and participating in safety committees and programs to assess, control and prevent EHS hazards; (c) developing and evaluating training programs; (d) conducting EHS-MS inspections and periodic compliance audits; and (e) taking appropriate corrective and preventive actions. It also requires that employees have quick and ready access to important EHS information, including EHS procedures/work instructions, hazardous material inventories and Safety Data Sheets (SDSs), exposure monitoring results, and injury and illness data and trends (among others). Further, employees must be free to report EHS related concerns without fear of retaliation from management, supervisors and peers, and a variety of common barriers to employee participation must be actively addressed and removed (e.g., language, literacy, disabilities and discrimination).
- Regulatory compliance – Requires an active and effective program to ensure each operation identifies and remains compliant with all relevant and applicable EHS laws, regulations and corporate standards of practice as well as external codes of conduct the company has endorsed. This includes requirements and provisions for (a) identifying all relevant and applicable EHS related compliance requirements; (b) documenting and updating all such compliance expectations and required activities; and (c) establishing documented programs and functions needed to achieve and maintain full compliance, including the establishment of a comprehensive site-wide EHS compliance calendar.
- Hazard identification and risk management – Requires each location to periodically identify, document and analyze routine and non-routine EHS hazards that could impact employees, contractors, temporary employees, or the environment (e.g., chemicals, biological materials and other workplace contaminants; electrical hazards; unguarded machinery; fire hazards; and loss of containment of hazardous materials). In addition, the risks associated with all identified hazards must be characterized, prioritized and ranked and adequate controls must be put in place to either eliminate or mitigate hazards. Such controls must be routinely verified to ensure they remain in-place and continue to be effective. Further, all locations must have an effective emergency response plan that is periodically tested, reviewed and updated.
- Education and training – Requires the periodic identification and documentation of EHS training needs, education requirements, and methods to determine the competency for all employees. In addition, each location must identify, develop and specify appropriate training, ensure that all required training is provided, and periodically evaluate its ongoing effectiveness.
- System evaluation and improvement – Requires each location to monitor and improve its entire EHS performance and implement measures that drive continuous improvement. This includes reviewing and verifying that the EHS-MS is operating as intended (and is achieving all company-wide commitments contained in our EHS Policy) as well as performing a complete management review of the system by top management. In addition, all locations must conduct their own internal audits of applicable EHS compliance requirements and programs at least annually, and mitigate any identified non-conformities through a documented corrective and preventive action process.
Corporate EHS Compliance Audit Program
In addition to requiring all applicable locations to implement and periodically verify their conformance to our EHS-MS Policy, and to conduct internal EHS compliance audits, our Corporate EHS Compliance Audit Program (operating independently of individual business unit control) conducts periodic, objective and evidence-based evaluations of each location’s EHS compliance status. Any observed deficiencies are documented and routinely reported to top management for action and response. An independent corporate corrective and prevented action process is also invoked that systematically drives closure of all outstanding EHS audit findings to full resolution in a timely manner.