TheCostsof

(Non) Compl iance

withEHSRegul ations
Author: Mr. Tjeerd Hendel-Blackford
Head of Thought Leadership, Enhesa
TheCostsof (Non) Compl iance
withEHSRegul ations
Author: Mr. Tjeerd Hendel-Blackford
Head of Thought Leadership, Enhesa

This publication is aimed at Global EHS Executives & Professionals and examines the cost of (not) complying
with environmental, health and safety (EHS) laws around the world. Not only is it cost effective to comply in
terms of dollars and cents, but it is cost efficient due to the many and varied benefits to your business that a
global EHS compliance program brings.

In t r odu ct ion

Ask yourself the following question...

How much does non-compliance with EHS laws and

regulations cost your organization annually,
globally?
Of course, this question is impossible to answer without further defining what we
mean by ?costs?. Do we mean direct financial costs, such as fines and
compensation? Indirect cost implications, such as loss of production or loss of share
price? What about the non-quantifiable costs, such as damage to brand reputation?
What if we flip the question and ask the following:
How much does compliance with EHS laws and regulations cost your organization
annually, globally?
For most companies who pro-actively manage EHS, an answer is likely readily
available since there is often a defined budget for this. For these companies, the
?costs? element is quantifiable. In this question, the definition of ?compliance?
becomes the focus ? but what does it mean and how do we measure it?
Are we confident we are as compliant as possible?

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 "What you don?t know can still hurt you,
in the form of penalties or injuries."

Th e Regu lat or y (Cost s) Ch allen ge f or Global M u lt in at ion als

Enhesa conducted a benchmarking survey of corporate EHS Executives in April 2017.
We found that:
- 74 per cen t had an enforcement action in the last five years (more than half
of which were in 2016 or 2017)
- Only 26 per cen t had had no enforcement action whatsoever in the past five
years (or, more likely, were not willing to share this information)
- Tw o-t h ir ds of the respondents had regulatory fines up to $100k resulting
from their recent non-compliance. An additional 10 per cen t experienced
fines in the range of $100k t o $500k .
Of course, these numbers represent only the instances where the companies have
been found to be non-compliant. Numbers would likely rise exponentially if all
internally identified non-compliances were discovered by the enforcing authorities.
Taking this one step further, we must also not forget the category of
non-compliances that haven?t been identified internally, due to lack of knowledge
about the law or lack of organized program for discovering them. What you don?t
know can still hurt you, in the form of penalties or injuries. Ignorance is no defense
under the law. In addition, it is worth noting that the regulatory fines only refer to
?the single, largest and most recent fine? incurred ? and therefore do not take into
account multiple fines during that period in the country in question, or the global
accumulation of total fines across an entire corporation. A regulatory fine is also
only part of the ?cost? story ? as we will examine further.
In February 2015, Enhesa carried out a separate survey amongst corporate EHS
managers on their confidence in the effectiveness of their corporate compliance
program. In an eye-opening result ? some 43 per cen t h ad lit t le or n o con f iden ce
t h at t h eir cor por at e com plian ce pr ogr am cou ld en su r e r egu lat or y com plian ce.
If we add to this mix the sheer volume of EHS regulations that exist across all the
global jurisdictions ? and the rate of change in those laws ? (Enhesa tracked more
than 4,000 regulatory and policy developments on EHS topics in 2016 alone) ? the
challenge is considerable and the cost implications significant.
So, what are the costs of not-complying?

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 Def in able Cost s of Non -Com plian ce
The U.S.A. leads the way
Let?s start with the numbers that we have publicly available and are therefore the
most reliable source of definable cost implications.

In the United States, the Environmental Protection Agency (EPA) recently published
the following highlights of its Enforcement Annual Results for Fiscal Year 2017:
- An increase in clean-up commitments by private companies to m or e t h an
$1.2 billion (from USD 1 billion in 2016).
- Near ly $20 billion in investments by companies in actions and equipment to
control pollution (up from USD 13.7 in 2016, and USD 5 billion in 2015!).
- An increase in the total of criminal fines, restitution, and mitigation to $2.98
billion.
- $1.6 billion in administrative and civil judicial penalties (higher than any of
the previous ten years, with the exception of 2016, but which included the
USD 5.7 billion BP was required to pay). By way f comparison, the total
collected in 2015 was just $207 m illion .
The numbers provided by the EPA clearly illuminate a critical truth: U.S. companies
are no longer exposed to court risks in the millions of dollars; environmental
enforcement actions are now collecting billions of dollars.
Although the 2017 change in administration in the U.S.A. is still in process of
implementing its regulatory and policy strategies, including an anticipated scale
back of Federal Regulations and (up to 30 percent of) the EPA?s budget, could
potentially still lead to a reduction in federal enforcement ? there are indications
that State-level enforcement ? and individuals, non-governmental organizations
(NGOs) and even companies taking action to ?do the right thing?, may result in
continued high-levels of scrutiny on industry.
Although the numbers only relate to environmental enforcement (and
environmental fines tend to be higher than those related to occupational health &
safety), the fines issued by the U.S. Occupational Safety & Health Administration
(OSHA) should also not be ignored. Notably, OSHA increased its fines in 2016 for the
first time in more than 25 years and this resulted in base levels of fines nearly
doubling. For example, prior to the changes the penalty for a willful or repeated
violation was $70,000 per violation. Following the adjustment rule, this is now
$124,708 per violation.

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 Def in able Cost s of Non ?Com plian ce
Enforcement on the rise in other countries
The U.S.A. has had a longstanding litigious and enforcement culture that makes it
stand out from other nations. However, there is a noticeable rise in other countries
around the world upping their enforcement efforts and associated penalties.
If we look at the UK?s Health & Safety Executive (HSE), which only pursues health and
safety cases, its latest prosecution data shows that UK businesses paid an average
of £58,000 in fines, for being found guilty of a health and safety breach in 2015 and
20165. The HSE enforcement statistics also show that the largest 20 fines to
businesses for health and safety violations in 2016 were three times more than the
largest 20 fines in 2015, and eight times higher than in 20146.
The largest fine imposed by the UK HSE in 2016 was £5 m illion on the theme park
operator Merlin Attractions, following a roller coaster accident 7. The second largest
fine was imposed on Cristal Pigment UK Ltd., a chemicals manufacturer fined £3
m illion when one worker was killed and another was left with life-changing injuries
when they were exposed to a toxic vapor cloud 8. Historically, these are big fines for
the UK.
The sizes of fines being imposed in the UK are clearly on the rise, and this is
expected to continue. In February 2016, new sentencing guidelines came into force
in the UK under which companies could face more than £10 m illion in costs for the
most serious health and safety violations, and more than £20 m illion for corporate
manslaughter convictions9.
The UK, like the U.S.A., has always been very active in enforcement prosecutions
(and publishing those). In many other countries, where this is less the case, it is
much harder to find concrete statistics on enforcement rates and levels of fines.
However, this is changing. To take one recent example in China, the Ministry of
Environmental Protection now publishes monthly news articles summarizing
enforcement actions that includes number of enforcement cases as well as amount
of fines. On 17 April 2017, it was reported that 239 com pan ies (out of 329
inspected in the Beijing-Tianjin-Hebei region), were to be charged with violations
related to illegally producing pollutants and lacking pollutant reduction
equipment 10.

"There is a noticeable rise in other countries around the world

upping their enforcement efforts and associated penalties."

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 Def in able Cost s of Non ?Com plian ce
Enforcement on the rise in other countries
If we take China as an example, the Ministry of Environmental Protection now
publishes monthly news articles summarizing enforcement actions that includes
number of enforcement cases as well as amount of fines.
Statistics from the Ministry show that, from January to November 2017, the total
number of cases where environmental enforcement penalties (including continuous
fines on daily basis, seizure, production restriction or suspension, administrative
custody, and criminal prosecution) are imposed increases 102.4 per cen t compared
to the same period in 2016 (that is, 35667 for 2017, 17620 for 2016). The continuous
fines on daily basis in the period amount to 1,075,400,000 CNY (approximately
$170 million), representing an increase of 43.4percent compared to the same period
in 2016. There is sharp increase of cases which lead to administrative custody, which
has increased 139.1per cen t (that is, 7827 in 2017, 3274 in 2016).[1]
There are increasingly high-profile enforcement cases in China as well.
For example:
- A German car parts manufacturer was indirectly impacted (self-claimed
losses of 300 billion yu an ($45.53 billion)) by closure of its main metal
wire-drawing supplier in Shanghai due to environmental law enforcement [2];
- Eight companies were sentenced to a penalty of 569 m illion yu an
($86 million) for the restoration of the contaminated soil and another
6 m illion yu an to a public welfare fund for environmental damage[3];
- Two truck makers were fined at least 38 m illion yu an ($5.84 million) for
emissions fraud [4];
- A company was sentenced to compensate for river water pollution caused by
44 t on s of phenol discharged from its inappropriate unloading operation [5].
The increased cases of environmental penalties and fines can be ascribed to the
large-scale environmental protection inspection drive announced by the Ministry of
Environmental Protection in 2017, and the strengthened continuous fine measures.
It is also worth noting that six Inspection Bureaus affiliated to the Ministry of
Environmental Protection have been established to reinforce regular environmental
inspection and enforcement [6].
The Ministry of Environmental Protection has also announced that it will launch a
second environmental protection inspection program in 2019[7].

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 ?The only way to lower the cost of workers?compensation in the long run
is to lower the frequency & severity of the claims that are driving those costs.?

Less-Def in able Cost s of Non -Com plian ce

Administrative fines and enforced remediation costs are just some of the obvious
(and highly publicized) consequences of failure to comply with EHS law. In the
Enhesa benchmarking survey, only 16 per cen t of companies said they did not
consider any other consequences to their business besides financial penalties.
Let?s discuss several other less-definable costs to consider?

Insurance and Worker Compensation

There are times, when non-compliance occurs or simply when accidents happen,
which create both a human risk and a financial cost. Often, insurance plans cover
the resulting damage, including coverage provided through workers?compensation.
Workers? compensation provides medical benefits and monetary benefits to
employees who are injured on the job in work related accidents.[1]
In many organizations, the EHS team and Human Resources coordinates and
administer the workers?compensation program. As with costs explored in litigation
and operational management, these costs add to the cost of compliance. Put
another way, ?workers?compensation is more like a finance tool than an insurance
policy? the only way to lower the cost of workers?compensation in the long run is to
lower the frequency and severity of the claims that are driving those costs.?[2]
In the U.S.A., NASI estimates that employers? costs associated with workers?
compensation totaled $94.8 billion in 2015 (an increase of $3 billion from 2014,
and a 20.1per cen t increase from 2011).[3] These costs include dollars spent for
insurance premiums, reimbursements, and administrative costs.[4]Workers?
compensation is limited to those U.S. states with participating coverage, but
provides insurance coverage in the event of a workplace injury or fatality.[5]
In November 2017, the Bureau of Labor Statistics provided the latest numbers
linked to work-related injuries.[6] The data, which is an analysis of the 2016 calendar
year, measured approximately 2.9 m illion recordable cases of nonfatal injuries and
illnesses in private industry.[7] Of those cases, 892,270 cases involved days away
from work, and the most frequent type of incident (with 317,530 recorded) were
cases involving sprains, strains and tears.[8] In addition, there were a total of 5,190
f at al w or k in ju r ies recorded in the United States in 2016, a 7 per cen t increase
from the 4,836 f at al in ju r ies reported in 2015[9]. The numbers are staggering.

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"Compliance with EHS laws can never provide an absolute guarantee
that disasters will never happen"

Less-Def in able Cost s of Non -Com plian ce (con t .)

Litigation Expenses
The numbers presented thus far are publicly available. There are of course many
cases in the EHS and risk sector that never see a day in court, are fully determined
outside of the courtroom, or are treated as entirely internal matters, away from the
eyes of the authorities. The costs associated with settlements (legal as well as the
actual settlement total) are figures that are pretty much impossible to examine
externally. To estimate what corporations spend defending actions in (or out of)
court is nearly impossible. Surveys attempting to estimate numbers are widely
varied and flawed. In 2010, a survey conducted of Fortune 500 companies found
that those companies spent $115 m illion on average in 2008 on litigation
expenses.20 This number does not include the amount spent on judgments or
settlements? only the dollar amount spent on actual litigation. Of the 36
companies that responded, the total amount spent on litigation was $4.1 billion.21
In a different survey conducted in 2008, the estimated cost of litigation was valued
at one-third of profits for Fortune 500 companies, or about $210 billion.22 These
figures are not limited to EHS actions but give a strong indication that the costs
surrounding EHS-related enforcement cases are likely to be extremely costly for any
corporation.

Ot h er Con sequ en ces of Non -Com plian ce

Physical Harm to People and/or the Environment
Linking all of these aspects together, worker deaths and catastrophic environmental
incidents are the most obvious and emotive reasons for acting safely and
responsibly. Be it a massive mine tailings spill in Brazil23 or an industrial explosion
that k illed at least 173 people in Tianjin, China,24 compliance with EHS laws can
never provide an absolute guarantee that such things will never happen: human
error, force majeure and unpredictability remain constant threats. However, when
such things do occur, there are no winners ? only massive losers. The knock-on
effects to business can also be felt for years if not decades afterwards, with
production shutdowns (such as those that impacted Toyota and John Deere),25
high-profile investigations (such as those impacting BHP Billiton and Vale),26 and
reactionary legislation (such as those adopted or being developed across Brazil)27
being covered in great depth and at great length by the media.
(continued on next page...)

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 "Enhesa?s benchmarking survey found that 96% of companies
recognize damage to reputation as a consequence of non-compliance."

Ot h er Con sequ en ces of Non -Com plian ce (con t .)

Criminal enforcement
In its 2017 enforcement report, the EPA also reported the imposition of 150
com bin ed year s of in car cer at ion for sentenced defendants. However, the U.S.A. is
increasingly not alone in pursuing criminal action. Criminal enforcement around EHS
management ? with penal sentences for corporate-level staff being held responsible
- is also on the rise around the world.
For example, from 1 January 2017, an interpretative judgment from the Chinese
Supreme People?s Court (SPC) took effect newly defining 18 t ypes of
en vir on m en t al cr im es as ?serious environmental pollution? and identified 13 t ypes
of ?ser iou s con sequ en ces? under China?s criminal law. This opens up a number of
additional infringements to the criminal courts as well as subjecting them to
increased penalties.28 A recent case has already highlighted this, when a Chinese
firm that produces dyed textiles, Dystar, received a penalty equivalent to $2.9
m illion for dumping several hundred tons of untreated liquid acid into a canal
between September 2013 and May 2014. Most notably, as part of the criminal
verdict, six of Dystar ?s managers were jailed for between t h r ee an d a h alf t o f ive
year s. 29

Brand & Reputation

In the last few years, high-profile public relations disasters have had long-term
impacts on many companies, for example:
- BP: Deepwater Horizon disaster in 2010 resulted in BP losing more than half
its value on the stock market- it has still not recovered fully, 30
- Volk sw agen: ?Emissions gate? scandal resulted in loss of nearly one quarter
of company values,31
- Glaxo Sm it h Klin e: In 2013, a corruption scandal involving payments to
doctors in China resulted in 3.5 percent slump in share price in London; and
most recently,32
- Un it ed Air lin es: enforced passenger removal incident went viral and
resulted in stock price falling33
These were all examples of the speed at which an issue can become global news,
permeating social media, resulting in damages to reputation, reduced sales from
consumer boycotts and in each case, a startling drop in the share value of the
company in question.
(continued on next page...)
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 Employee Culture & Values
Another cost element that is hard to define is the impact regulatory non-compliance
incidents can have on the morale of employees and the overall workplace culture.
Existing employees are likely to see drops in productivity as a result of incidents that
can impact p hysical and mental health. Talented potential future employees will
also think twice about coming to work for a company that has a poor safety or
environmental protection reputation. The costs to business of these factors are
impossible to quantify ? they are both short and long term ? and simply ignoring the
issue will definitely NOT add to your company share price.

Def in able vs Less Def in able Cost s of Non -Com plian ce

A 2011 Ponemon Institute study of global multinationals undertaken in the U.S.
indicated that the direct costs (fines, revenue loss, etc.) only accounted for less than
one third of the costs of non-compliance. However, indirect and opportunity costs
such as loss of information, stoppage in production, or diminished employee
productivity and lost business opportunities that result from compliance infractions
are often six to ten times more than direct costs.34 It is important to note that the
report was not solely focused on EHS compliance, but rather on compliance with
data security and protection laws. Despite this, given the other elements discussed
in this publication, it is easy to draw parallels.

Percentage Cost Structure for Non-Compliance Costs

Similarly, a study by the HSE in the UK, and reported on by the Royal Society for the
Prevention of Accidents (ROSPA) estimated that the ratio between insured and
uninsured costs arising from accidents lies in the range of 1:8 t o 1:36.35 This would
mean that in the worst case, for every unit of cost recovered from the insurer, the
business would lose up to 36x that amount in ?hidden? costs.

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 Th e Cost of Com plian ce
The costs of non-compliance have been examined in some depth. What about how
much it actually costs to (as much as possible) comply?
This is of course a relatively open-ended question and for many companies
represents sensitive information. Looking at the question on the basis of our recent
benchmarking survey results, which focused on companies operating at least 50
sites globally, we can already identify a few key points regarding their overall
compliance program:
- 55 per cen t of companies surveyed have an enterprise-wide software system
and/or regulatory information service (like Enhesa) that is paid for by
corporate that each country/site utilizes. An additional 3 per cen t use a
network of consultants or lawyers also paid for out of a corporate budget.
This is encouraging.
- On e in t h r ee companies have no corporate budget, instead letting individual
sites (or regional structures) budget for this.
- Perhaps most shockingly, 10 per cen t of companies have no such service or
tool and no budget for compliance management, at all.
For the purposes of our survey we then broke this down into two separate aspects:
a. The cost of managing compliance against today?s EHS laws (on-going
compliance management); and
b. The cost of monitoring and tracking up-and-coming EHS regulation
and policy (regulatory forecasting)
With regards to the question of how much companies spend on managing EHS
regulatory compliance (excluding third-party auditors) ? the results of our (strictly
anonymous) survey were also illuminating:
- 18 per cen t have NO specific budget at all for this ? another 18 per cen t of
respondents did not want to divulge this figure.
- On e in t h r ee companies said that they have no global budget (instead letting
sites pay for this) and spend $10k < per sit e annually on managing EHS legal
compliance. However, as our study also categorized companies on the basis
of number of global location, we can roughly estimate that the range of
annual budget would be up to $50k globally for a company operating
around 50 sites ? to more than $500k for companies operating more than
500 sites globally. That being said, the obvious potential inaccuracies of such
estimates highlights the serious challenges for those companies on two
levels:
(continued on next page...)

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 Th e Cost of Com plian ce (con t .)

a. Not only is it nearly impossible to analyze the complete overall

spending and effectiveness of a program; but also
b. EHS compliance assurance solutions used in different locations are
likely to vary in functionality; robustness, application and capabilities ?
meaning that any picture on compliance is likely to be haphazard at
best.36
Of companies that did respond, one in three have a budget of between $25k an d
$100k annually to fund a global compliance program. 18 per cen t of companies
have a global budget of $100k t o $500k . This is interesting as it highlights the fact
that the costs of getting local sites to fund a compliance program are perhaps not
that different from companies with a global budget ? in which case the benefits of a
global approach, over a local one, really become a crucial factor.37
None of the respondents?companies had an annual budget higher than $500k for
ensuring on-going EHS compliance management globally.
On the same question regarding budget for a separate service to monitor and track
(forecast) regulatory and policy developments and the key results in this case were
very clear in demonstrating the divergent approaches between companies:
- 35 per cen t of companies had no specific budget for a service to keep track of
regulatory change
- 17 per cen t of companies had no global budget and spent >$10k per site
annually
- 35 per cen t of companies have an annual global budget for a service that
ranged from $25k t o $100k
- 13 per cen t spend between $100k an d $500k annually on a service
So, there is a nearly 50/50 split between companies taking a global, proactive
approach to staying on top of up-and-coming regulatory issues ? and those that do
not.
If we combine the results of the different elements of the benchmarking survey with
an analysis of our typical best-practice client-spending on a global program to help
ensure compliance AND stay on top of regulatory changes we can make the
following general observation:
For a comprehensive global EHS regulatory compliance program (incorporating both
regulatory analysis; compliance management and regulatory change forecasting
elements) ? a large multinational company will typically budget somewhere between
$100k an d $750k annually to cover ALL their global sites in a consistent and
standardized manner (depending on the size of the company).38

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 Con clu sion
Th e Cost of Com plyin g vs. Non -Com plian ce
Does a Global EHS Regulatory Compliance program represent value for the money spent?
Based on a rudimentary analysis of the figures quoted in this publication, the
answer would be an unequivocal YES. Whether you consider an investment in a
global EHS program as an insurance cost, or a fundamental part of the business
strategy ? the varied benefits, both definable and non-definable ? speak for
themselves.
This conclusion is backed up by several other sources that analyzed the costs of
pro-actively managing compliance ? against not doing so. For example:

The Ponemon Institute report 39 referenced above, which was based on 160 interviews
conducted across 46 large organizations, and found that, on average,
t h e cost of n on -com plian ce is 2.65x t h e cost of com plian ce

Similarly, in a study conducted by Arinite, a UK health & safety consultancy, it was found that on average,
f in es f or h ealt h & saf et y in f r in gem en t s w er e 65 per cen t h igh er t h an t h e cost of com plyin g40

The National Safety Council in the U.S. also references studies that show that
$1 in vest ed in in ju r y pr even t ion r et u r n s bet w een $2 an d $641

Countries where there had been less attention paid to enforcing environmental and
workplace safety issues in the past are now finding their feet. Compliance with EHS
laws is becoming a global necessity for business, where previously it may have been
viewed as a luxury. Countries that have traditionally been at the forefront of EHS
regulatory enforcement, such as the United States, the United Kingdom and
countries within the European Union continue to be, while other countries such as
China and Japan have significantly stepped up their enforcement programs, both in
severity and frequency, joining in on the trend of imposing heavy fines and even
prison sentences for non-compliance as well as publishing and, on many occasions,
publicizing enforcement cases. This creates serious challenges for multinational
corporations to know what national legislation they need to comply with. In
particular, as major multinationals expand their operations outside of their home
markets, they are increasingly exposed to more intense scrutiny and stepped-up
enforcement.
(continued on next page...)

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Of course, the global challenge is to achieve high levels of compliance while
watching the bottom line. Many companies are choosing to move away from
third-party audits and are bringing their EHS compliance auditing in-house, using a
reliable, consistent source of global regulatory intelligence, in combination with
user-friendly tools, such as those provided by Enhesa42 to carry out audits or
manage compliance on an ongoing basis, thereby reducing expenses while
effectively supervising regulatory compliance worldwide.
It is clear now more than ever that EHS risks are becoming a tremendous force to be
reckoned with. Compliance and the costs associated with it are affecting the
day-to-day productivity of growing organizations. Regulators are becoming
increasingly stringent and consumers actively go in search of responsible
companies. A robust EHS compliance program cannot be built overnight, but,
investing in a program that is proactive, flexible and prepared is crucial. In
conclusion, the average cost of a compliance program well outweighs the risks,
monetary and otherwise, that a company is vulnerable to without one. In fact, an
investment in EHS compliance is more than just an investment in protecting the
environment and your employees; it is also an investment in Marketing & Sales; HR;
R&D; Productivity; Legal Assurance and Insurance.43

It is an investment that pays back in spades.

enhesa.com

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 Ref er en ces
1. https://www.epa.gov/enforcement/enforcement-annual-results-fiscal-year-2016
2. Id.
3. https://www.epa.gov/enforcement/deepwater-horizon-bp-gulf-mexico-oil-spill
4. https://www.osha.gov/Publications/OSHA3879.pdf
5. http://www.hse.gov.uk/statistics/enforcement.pdf?pdf=enforcement
6. http://www.hse.gov.uk/statistics/enforcement.htm
7. http://press.hse.gov.uk/2016/alton-towers-owners-fined-over-smiler-crash/
8. http://press.hse.gov.uk/2016/chemical-company-fined-3mil-after-the-release-of-toxic-vapour-cloud-on-two-separate-occasions/
9. https://www.sentencingcouncil.org.uk/wp-content/uploads/HS-offences-definitive-guideline-FINAL-web1.pdf
10. http://english.mep.gov.cn/News_service/media_news/201704/t20170417_411614.shtml
11. https://www.ssa.gov/policy/docs/ssb/v67n1/v67n1p17.html and
https://www.nasi.org/press/releases/2016/10/press-release-workers%E2%80%99-compensation-benefits-share-payrol
12. http://www.cavignac.com/wp-content/uploads/2013/09/Q3-2013-Construction-Newsletter.pdf at 2
13. https://www.nasi.org/press/releases/2016/10/press-release-workers%E2%80%99-compensation-benefits-share-payrol
14. Id.
15. https://www.ssa.gov/policy/docs/ssb/v67n1/v67n1p17.html
16. https://www.bls.gov/news.release/archives/osh_10272016.pdf at 1.
17. https://www.bls.gov/iif/
18. Id.
19. http://www.workcompprofessionals.com/why-there-are-too-many-slips-trips-and-falls/
20. http://www.uscourts.gov/sites/default/files/litigation_cost_survey_of_major_companies_0.pdf , 2-3
21. http://www.uscourts.gov/sites/default/files/litigation_cost_survey_of_major_companies_0.pdf at 4
22. http://www.metrocorpcounsel.com/pdf/2008/February/28.pdf
23. https://www.theguardian.com/sustainable-business/2015/nov/25/
brazils-mining-tragedy-dam-preventable-disaster-samarco-vale-bhp-billiton
24. http://time.com/3994621/explosion-tianjin/
25. http://www.bbc.com/news/business-33955783
26. http://www.reuters.com/article/us-brazil-mining-samarco-idUSKCN114259
27. https://www.theguardian.com/world/2015/nov/10/brazil-dam-burst-mining-rules
28. http://news.sina.com.cn/o/2016-12-26/doc-ifxyxvcr7613078.shtml [in Chinese only]
29. http://news.xinhuanet.com/english/2017-01/07/c_135962989.html
30. http://marketrealist.com/2014/09/bp-lost-55-shareholder-value-deepwater-horizon-incident/
31. https://www.bloomberg.com/news/articles/2015-09-21/volkswagen-drops-15-after-admitting-u-s-diesel-emissions-cheat
32. http://edition.cnn.com/2013/07/25/business/china-glaxosmithkline-bribery-corruption-scandal/index.html
33. http://www.cnbc.com/2017/04/12/shares-of-united-fall-for-second-day-as-controversy-lingers.html
34. http://www.ponemon.org/local/upload/file/True_Cost_of_Compliance_Report_copy.pdf
35. http://www.rospa.com/occupational-safety/advice/business-case/
36. http://www.enhesa.com/flash/10-reasons-go-global-ehs-compliance
37. http://www.enhesa.com/flash/10-reasons-go-global-ehs-compliance
38. N.B. This figure does not factor in the cost of 3rd party auditors or the cost of any 3rd party software integration.
39. http://www.ponemon.org/local/upload/file/True_Cost_of_Compliance_Report_copy.pdf
40. http://www.arinite.co.uk/the-cost-of-health-and-safety-compliance-vs-a-prosecution-fine/
41. http://www.safetyandhealthmagazine.com/articles/10414-the-roi-of-safety?page=2
42. Enhesa?s Compliance Intelligence allows on-assessment of regulatory compliance globally, and can be used as within Enhesa?s Audit
Scorecards and/or Compliance Dashboard, or in various 3rd-party partner software platforms. Learn more at www.enhesa.com
43. https://www.linkedin.com/pulse/price-safety-your-ehs-budget-tjeerd-hendel-blackford

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