The analysis risks to Safety and Health in the workplace and the Environment covers generic risks related to industrial activities and specific risks related to the own activities of the Suppliers and Subsidiaries.
As is the case for any production (manufacturing and packing), distribution, research and general administration operations, the Group and its Suppliers are exposed to safety and environmental challenges.
Based on the risk prevention work on the Environment, Health and Safety at the workplace carried out by L’Oréal for many years, the major risks listed below have been identified. On this basis, the Subsidiaries and Suppliers must define at each of their sites, the measures designed to prevent the risks identified in this Vigilance Plan (the “Prevention System”).
The Subsidiaries conduct their own risk analysis based on the list of risks below, particularly the fire risk that is framed by very strict fire prevention standards (National Fire Protection Association standard).
In addition to the generic risks, the Subsidiaries identify the specific risks related in particular to cosmetics production. Thus, for example, the physical risks are the subject of SHAP (Safety Hazards Assessment Procedure) studies, which identify the dangers, generally and for each workstation, assess the risks and allow the implementation of the necessary means of control. Similarly, environmental risks are analysed to characterise the aspects and impacts of site activities on its environment and to control those that lead to potentially serious impacts for the air, soil, water, biodiversity and resources.
This environmental analysis is updated regularly by each of the Group Subsidiaries’ sites and whenever a significant change occurs. If significant risks are identified or if L’Oréal’s standards or regulations impose specific requirements, a more detailed evaluation is carried out for the activities concerned. Appropriate action plans – with immediate action where necessary – are implemented to reduce significant risks to an acceptable level.
With regard to water discharge, each industrial site has implemented a self-monitoring system that is representative of waste water discharged (monitoring of regulated and contractual parameters: chemical oxygen demand (COD), oxygen biochemistry demand (OBD), etc.). This self-monitoring is a tool for detecting risks of exceeding regulatory thresholds that helps to anticipate any non-conformities and initiate corrective actions. More over, 31 L’Oréal factories have their own wastewater treatment plant and L’Oréal is continuing with the installation of these plants.
The risks of process safety are analysed using the HAZOP (HAZard and OPerability analysis) guide, which focuses on operating conditions, or FMECA (Failure Mode, Effects and Criticality Analysis), which analyses risks related to failures in the process at the different steps in production.
The results and means of controlling industrial and specific risks are summarised in the GHAP (Global Hazard Assessment Procedure) programme.
Suppliers, in addition to their own risk analysis, rely at a minimum on the risks identified in the audit grid provided by L’Oréal at the signing of the Letter of Ethical Commitment (see section 4.3.1.2.1. “Due diligence: selection and assessment of strategic suppliers” of this document) in order to implement suitable preventive measures in each affected site. This grid was prepared in accordance with the list of the major risks described below and is applied during referencing and follow-up audits.
If the specific nature of the Suppliers’ activity requires identification of specific risks and/or additional prevention measures, the Suppliers are required to roll out these additional measures in accordance with best practices in their industry.
For example, in the subcontracting of finished products activity, specific risks may involve:
In the specific case of subcontracting suppliers of aerosol production or storage, bleaching powders, flammable products, the sites are subject to specific risks analyses concerning process safety.
(i) Risks associated with buildings and the use of equipment:
(ii) Risks related to energy sources, matter and materials: Risks related to energy sources, matter and materials:
(iii) Risks related to human activities:
