HSE requirements for small and large companies

Short answer

The Norwegian HSE rules apply to every company with employees, small or large. Everyone must work systematically on health, safety and the environment. The requirements are adapted to size and risk: a company with five employees can keep it simple, while a company with many departments needs more structure. Some requirements apply from a certain number of employees.

Do the rules apply to us?

The Working Environment Act applies to businesses that have employees. If you have employees, you are also responsible for their working environment. That is true whether you are five, fifty or five thousand.

The Act says the employer must ensure systematic work on health, safety and the environment (section 3-1). This means HSE is not something you do once. It is work that is planned, carried out, followed up and improved.

The Internal Control Regulations in brief

The Internal Control Regulations describe what the systematic work must include. The Regulations have eight points. In our own words, they are about:

Having an overview of the laws and rules that apply to the company.
Employees having enough knowledge of HSE, also when things change.
Employees being able to take part and contribute.
Goals for the HSE work.
Who is responsible for what.
Mapping hazards, assessing risk and making plans and measures.
Procedures for detecting, correcting and preventing errors.
A regular review that it all works.

Points 4 to 8 must be documented in writing. The Regulations also say the internal control and the documentation must be adapted to the nature, activities, risks and size of the business. Read the full Regulations on Lovdata (in Norwegian).

What does “adapted to size” mean?

The requirements are the same, but how you meet them depends on how large you are.

Few employees. You do not need a thick binder. Short, up-to-date documents that are actually used are better than long documents nobody reads. Often the managing director carries most of the responsibility personally.
Many employees. Responsibility is spread across several managers, departments and perhaps several sites. Then it matters that everyone works the same way, that responsibility is written down, and that management can see what is happening across the whole company, not just in one department.

The same applies to everyone: the requirements must actually be met, and you must be able to show what you have done.

Requirements linked to the number of employees

Safety representative

The main rule in section 6-1 of the Working Environment Act is that a safety representative must be elected in every business the Act applies to. Businesses with fewer than five employees can agree in writing on a different arrangement. The Labour Inspection Authority can still decide that there must be a safety representative.

Working environment committee

Under section 7-1 of the Working Environment Act, businesses that regularly have at least 30 employees must have a working environment committee. If you have between 10 and 30 employees, a committee must be set up if one of the parties asks for it. Check the current text on Lovdata, as the thresholds have changed in recent years.

Training for you as a manager

The employer must personally complete training in HSE work (section 3-5 of the Working Environment Act). The Act does not say how many hours it must be.

A simple checklist

Write down the goals for the HSE work.
Write down who is responsible for what, also in each department if you have several.
Map the hazards and assess the risk. See the guide on risk assessment.
Set up a procedure for reporting and following up deviations.
Elect a safety representative, or make a written agreement if you are fewer than five.
Check whether you need a working environment committee.
Review everything at least once a year, and fix what is not working.

How the portal helps

The portal has an overview of the requirements in the Internal Control Regulations, templates for risk assessments and safety inspections, deviations that notify the person responsible, and an HSE annual plan. That makes it easier to keep the work going and to show the documentation, whether you have one department or many.

Read about the HSE system

Sources

The rules change. Always check the current text with the sources below. Most sources are in Norwegian. This guide is general information and not legal advice.