We admit that the majority of articles about conflict minerals are not particularly exciting reading – including our own.
A recent exchange in the Forbes blog is different. While we take no position on the facts or opinions presented by either party, we do find this repartee far more interesting reading than we are accustomed to seeing on the topic.
Read the first piece here, the initial response here and the third installment here. Will there be more? We can only guess.
Posted in conflict minerals, EHS, Governance, HSE, sustainability
Tagged coltan, Conflict Minerals, Congo, corporate responsibility, csr, Dodd-Frank, DRC, EHS, Forbes, SEC, Securities and Exchange Commission, supply chain, sustainability, tantalum, tin, tungsten, wolframite
It is not uncommon for EHS auditors to be asked (or ask themselves) “If you find a noncompliance during your audit, do you report it to the regulators?”
The answer depends on the company and audit program, but a recent news item caught our attention due to a variation on the theme.
We have no information other than what is publicly available here, but it appears that an organization managing a voluntary electronic waste management certification program found alleged significant non-conformities at a specific company seeking certification. As a result, the organization declined to issue its certification to that company.
So far, so good, but the story doesn’t end there…
In its declination letter to the company, the organization states:
Further, there is substantial reason to believe that such exports may violate Public Act 095-0959 (Electronic Products Recycling and Reuse Act, recycler requirements) of the State of Illinois, the Federal CRT Rule, (40 CFR Parts 9, 260, 261, 271; Cathode Ray Tubes; Final Rule) as well as the waste importation laws of Hong Kong/China. Further, while it is not our policy to disclose the results of certifying body audits, we can state that the audit only further substantiated all of our concerns.
In an apparent contradiction to the “policy” referred to in the above statement, the organization’s cc’d “Selected news media”, the Illinois State Environmental Protection Agency and the US Environmental Protection Agency Enforcement on its letter, which can be seen below the signature block.
It is certainly possible that the company themselves had made prior disclosure to the regulators on this issue. But this event may cause companies pursuing voluntary programs/certifications to carefully consider how the company and auditor will manage regulatory non-compliances that are found or alleged in the course of related audit activities.
UPDATE: Reports today indicate that the company is taking legal action against the certifying organization stating that the allegations on which the organization based its decision – as well as its disclosure to the press and regulators – are false.
Posted in Auditing, Compliance, EHS, HSE, risk management
Tagged audit, auditing, compliance management, corporate responsibility, disclosure, e-waste, EHS, electronic waste, EMS, Environment, environmental compliance, environmental risk, internal controls, ISO, recycling, risk management
On Tuesday May 31, The Elm Consulting Group International LLC will formally announce a major development in our conflict minerals traceability services.
Lawrence Heim, Elm Director and leader of the firm’s conflict minerals services:
SEC’s delay in promulgating their final conflict minerals rule has resulted in a significant amount of uncertainty within affected companies. Many of these companies are challenged by cost constraints as they seek information, guidance and solutions to yet-unknown compliance standards. Our announcement next week provides a highly cost-effective solution in balancing these challenges.
If you would like to receive the announcement and related information directly, send an email to Lheim@elmgroup.com.
Posted in Auditing, conflict minerals, Governance, HSE, risk management, sustainability
Tagged audit, cassiterite, coltan, columbite, compliance management, Conflict Minerals, Congo, corporate responsibility, Dodd-Frank, DRC, EHS, Environment, environmental, environmental compliance, internal audit, internal controls, SEC, Securities and Exchange Commission, supply chain, sustainability, tantalite, tantalum, tin, traceability, tungsten, wolframite
The new issue of iPhoneLife magazine highlights Elm’s use of iPads for environmental, health and safety audits in a short feature.
Unfortunately, the article indicates we use them for energy audits, which is not the case. We have contacted the editor to inform them of their error.
Interestingly enough, the current issue also reviews various notetaking apps for anyone interested in reading up on the subject.
Posted in Auditing, EHS, Governance, H&S, Health & Safety, HSE, sustainability
Tagged compliance management, EHS, EHS Auditing, Environment, environmental, environmental compliance, Health & Safety, internal audit, iPad, risk management
Elm is featured in today’s issue of the on-line news source Mashable for our innovative use of the iPad for HSE auditing. The article can be read here.
With a reported 30+ million monthly pageviews and an Alexa ranking under 250, Mashable ranks as one of the world’s largest websites. The website has a large following on many social networks. As of February 2011, it has over 2 million Twitter followers and over 425,000 fans on Facebook.
Posted in Auditing, Compliance, EHS, Environment, H&S, Health & Safety, HSE, sustainability
Tagged audit, audits, EHS, Environment, environmental, HSE, internal audit, iPad, Mashable, sustainability, technology
Join us for an upcoming webinar Friday, February 25 about using the iPad in HSE audits. We will present an overview of our experiences in using the device on actual audits over the past 6 months.
Included in the presentation will be a discussion of
- evaluating its potential use and fit within organizations/existing audit processes;
- benefits and limitations; and
- a detailed step-by-step simulation of an audit using Elm’s selected application (smartNotes), including actual screen shots.
The hour-long presentation will be followed by an open question and answer period.
Click here for a full description. There will be a morning session and an afternoon session. Click here for the afternoon session.
We hope you can participate.
Posted in Auditing, Compliance, EHS, Environment, H&S, Health & Safety, Risk, sustainability
Tagged audit, auditing, EHS, Environment, HSE, iPad, protocol, Safety
The Elm Consulting Group International LLC, a specialty health, safety, environmental and sustainability (HSES) management consulting firm, is pleased to announce the addition of Joseph B. Cotier, CPEA as a Director of the firm beginning January 3, 2011.
“Joe brings 22 years experience in HSE auditing excellence and client focus to our team” said Patrick Doyle, Elm’s founder and Managing Director. “He is a perfect complement to the firm.”
“I have known Joe personally and professionally for close to 20 years and know first hand about his expertise and exemplary qualifications. We are very excited to have him become a part of Elm” said Robert Bray, Elm Co-Founder and Managing Director.
Cotier said, “I am happy to be a part of Elm and look forward to continuing to have a positive impact on the HSE auditing field – driving innovation both in the US and across the globe.”
Joseph B. Cotier, CPEA, has completed more than 350 EHS audits and management systems consulting projects in more than 35 states and 20 countries. He has experience in a wide range of industries including petroleum refining and chemical manufacturing, electric utilities, breweries and consumer and pharmaceutical products manufacturing. Mr. Cotier is an air emissions expert with particular strengths in emissions inventories, leak detection and repair, and a wide variety of MACT programs. Joe his has performed inspections and managed compliance orders as a Senior Air Pollution Control Engineer for the Connecticut Department of Environmental Protection. He is a BEAC Certified Professional Environmental Auditor and recently completed his fifth year on the Board of Directors for The Auditing Roundtable, the leading professional association for HSE auditors. He served as Secretary, Vice President and President, and now serves the Roundtable as Director on the Board.
Mr. Cotier will be working out of Glastonbury, Connecticut and can be reached at email@example.com, +1-860-794-3617 (cell) or +1-860-430-1653 (office).
Posted in Auditing, Compliance, EHS, H&S, Health & Safety, HSE
Tagged audit, BEAC, compliance management, cotier, EHS, emissions, Environment, environmental, environmental risk, EPA, greenhouse gas, HSE, internal audit, internal controls, OSHA, risk assessment, risk management
Following a successful implementation of the iPad for HSE auditing, Elm is today rolling out environmental compliance audit protocol modules for field testing this week.
“We believe this is the first formal environmental audit protocol implemented in the iPad form factor,” said Lawrence Heim, Director of Elm’s Georgia operations and the firm’s lead for iPad service development.
The protocols are reflective of a traditional paper-based format proven in the field over a number of years. Modules selected for field testing are waste generation, Emergency Planning and Community Right-to-Know (“EPCRA”) and ozone depleting substances.
“In our view, this as a potentially dramatic step forward in HSE auditing. While version one does not automatically generate audit findings or reports, it has other significant strengths in addition to the benefits already seen by Elm from iPad implementation,” Heim said.
Elm highlights the following features:
- Flexibility. The protocol can be used in a manner matching auditors’ own personal styles in collecting audit data. Handwritten notes are captured in any format, including different “ink” colors, “highlighters”, and line weighting. While the initial protocol version is based on Elm’s standard audit process, other custom formats can be developed virtually without limitation.
- Adaptability. Elm’s iPad HSE protocol can be used alongside existing audit systems for initial data capture and organization prior to entering the information into less user friendly, highly structured audit systems. Also, the resulting PDF file can be attached into other HSE audit systems as supporting documentation.
- Merging related documents into the protocol. Documents such as state regulations, permits, plans, applications, agency correspondence and enforcement agreements can be incorporated into the protocol itself without effort of retyping, restructuring or reformatting. Once the appropriate document is merged, auditors are able to write notes and highlight text directly in the document. Further, by using a cellphone camera, additional documents can be captured and merged into the protocol in a few minutes while on-site.
- Languages. The iPad application in which the protocol was created can drastically reduce the need to translate audit protocols and related documents between languages. Audit documents are captured in their source format and original language, eliminating language translation costs/errors and allowing auditors to use their local language.
“We fully expect a successful test, with only minor changes to Version 1 being necessary. Additional environmental compliance modules are already in initial stages, awaiting our assessment of the field trials. Health and safety modules will be developed soon after,” Heim stated.
Posted in Auditing, Compliance, EHS, H&S, Health & Safety, HSE, Safety
Tagged audit, auditing, EHS, Environment, environmental, environmental compliance, EPA, H&S, HSE, internal audit, internal controls, iPad, OSHA, protocol, Safety
We recently announced our trial of and results from using an iPad for EHS auditing. These articles were intentionally short and provided summary information.
We were subsequently contacted by the Editor of EHS Journal to provide a more detailed article for their respected publication. That article is now available.
We invite you to read it.
Posted in Auditing, Compliance, EHS, H&S, Health & Safety, HSE, risk assessment
Tagged audit, auditing, compliance management, EHS, Environment, environmental, environmental compliance, environmental risk, health and safety, HSE, internal audit, iPad, risk management, Safety