An Inconvenient Reality For Environmental/Sustainability Professionals?

For years, those of us in the environmental/sustainability profession have sought credible ways and metrics for quantifying the economic value of our efforts, activities and programs.  A myriad of studies completed dating back to the late 1980s attempt to demonstrate “environmental value”.  Most of these studies have shown rather tenuous linkages or used meaningless metrics.

Interestingly, most of these studies link to equity markets – i.e., stock prices.  Maybe because stock prices grab headlines, are tied to compensation or are the target to which Boards and senior executive generally manage.

The problem is that environmental/sustainability matters don’t fit into this model, either because they tend not to be financially material, or they don’t develop economic certainty within the “current quarter” myopia of corporate management, financial markets and analysts.

A recent article on the topic was published in The International News.  The article includes an interview with Kevin Parker, CEO of Deutsche Asset Management (DeAM) on the subject of how capital markets currently view environmental/sustainability risks.  DeAM manages over US$775 billion in assets.

With simplicity, clarity and unquestionable credibility from the financial market viewpoint, Parker made key points in the article and interview:

• Bond markets are poised to punish polluting companies in the aftermath of the Macondo oil spill and Fukushima nuclear crisis.
• “The process of re-pricing carbon and environmental risk has begun, because these two events were catastrophic.”
• By contrast, shorter-term equity and commodity markets have continued to chase high-carbon opportunities, including voracious emerging market demand for coal.
• But investors in longer-term debt including bonds will increasingly avoid unsustainable companies … an inexorable trend that will push up their borrowing costs.
• “What this boils down to be risk in capital markets, and capital markets know how to price risk once they understand it.”

Pension investment managers realized this years ago since they emphasize stability and a long-term investment horizon.

But there seems to be far less recognition of this by environmental/sustainability practitioners, as the amount of studies, white papers and pseudo-financial metrics is mounting, with continued emphasis on the equities side of capital markets.  Perhaps the driving forces for this are general economic pressures facing companies are pushing staff to find ways to justify their existence and cost, consultants are trying to come up with that elusive short-term ROI metric for the cost of their services to clients and much of the HSE/sustainability media are vying for limited attention on the part of their readership.

Given Parker’s comments – and the lackluster historical success of valuation of environmental/sustainability matters in the context of stock prices – perhaps it is time to redirect our efforts at finding relevant and credible metrics.

In limited circumstances, financial value of environmental/sustainability initiatives can manifest in material and short-term impacts.  Those instances give practitioners hope of riding those coattails.  But generally, the reality is a little inconvenient.

Revision to SICMAP℠ Tool for Conflict Minerals, OECD Incorporates California Supply Chain Law

The Elm Consulting Group International LLC has released a new revision to the Self Implemented Conflict Minerals Audit Preparation Tool.  The update, Revision 1.33, incorporates

• Minor changes in response to feedback obtained from the late June EICC Extractives Supply Chain Workshop VI in Washington DC;
• Further clarifications on the OECD framework, its relationship to SICMAP℠  and SEC auditor standards; and
• Related elements of California Transparency in Supply Chains Act of 2010.

Lawrence M. Heim, CPEA, is leading the firm’s conflict minerals services and SICMAP℠ development:

In our discussions with various companies and workshop attendees, we obtained feedback on a few minor changes and clarifications to improve the tool.  In addition, we decided to incorporate the new California law as there are many similarities between those mandates and the conflict minerals requirements.

The video introduction and overview of SICMAP℠ can be viewed here.

Elm Launches Groundbreaking Low Cost Conflict Minerals Audit Preparation Tool

The Elm Consulting Group International LLC today announces a groundbreaking cost effective tool to support companies preparing for conflict minerals traceability audits or customer inquiries.

The delay in SEC’s final rule triggered many questions from companies about planning and pre-audit preparation.  This led us to a solution that is valuable in almost any foreseeable final regulation scope/content and companies planning responses to customer inquiries – yet significantly reduces costs during this period of uncertainty.

Elm’s Self-Implemented Conflict Minerals Audit Preparation^© (SICMAP℠) is conceptually similar to a self-audit checklist.  SICMAP℠ is a spreadsheet tool that maximizes the use of internal company staff for cost reduction and implementation flexibility to develop and review conflict minerals programs in advance of third party auditing.

SICMAP℠ focuses on basic program elements equally relevant to companies responding to customer inquiries/procurement requirements and those working to comply with the upcoming SEC regulations on conflict minerals.   Successive and more complex tasks – for both program development and audit preparation – are identified based on initial SICMAP℠ findings, lessons learned from working through the SICMAP℠ process, and the final regulatory requirements once they are known.  The final rule, when published, will clarify the level of detail for some of the efforts.

Screenshots (which can be enlarged by clicking on them) show some of the features and functionality in SICMAP℠ include:

• “At a glance” color-coding indicates progress/status of both program development and audit preparation
• Live links to reference materials on the internet
• Summaries of language from the U.S. legislation (which will not be changed by SEC’s final regulations)
• Step-by-step pragmatic guidance on specific program elements
• Highlights of emerging international initiatives in comparison/contrast to SEC audit standards

Sample Page Showing Detailed Guidance

Topics covered in an intuitive and pragmatic way include:

• Initial scoping
• Reasonable assurance and representative sampling concepts reflecting SEC auditor standards
• Information management systems
• Internal controls
• Supply chain mapping
• Communications planning and content
• Scrap materials – special definitions and challenges in traceability efforts
• Considerations in selecting an auditor and preparing for the site visit

Summary Tracking Page With Color Coding. This image shows covered topic tabs along the bottom.

The tool is based on Elm’s experience as one of four firms worldwide that have completed conflict minerals traceability independent audits. Elm’s tantalum traceability audits in 2010 resulted in the first ever “Conflict-Free Smelter” designation^*, covering sites in the US and Japan.

We continue to recommend that companies move forward with planning activities, but defer third party audits until planning is substantially complete and the SEC regulations are final.  As with almost any new management program, a formal third party audit should be the last step of the implementation process – not the first.

SICMAP℠ will be commercially available beginning June 6, but feel free to contact us beforehand with questions.

* Issued by the industry association sponsoring the audits.  The Conflict Free Smelter (CFS) program is emerging as the leading conflict minerals third party certification program for smelters by the electronics industry.

Elm to Make Major Conflict Minerals Service Announcement May 31

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.

Elm Featured in iPhoneLife Magazine for iPad Use

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.

Elm’s iPad Auditing Featured in One of the World’s Most Visited Websites

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.

Joseph Cotier, CPEA joins The Elm Consulting Group International LLC

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 jcotier@elmgroup.com, +1-860-794-3617 (cell) or +1-860-430-1653 (office).

The Elm Consulting Group International LLC Launches iPad Environmental Audit Protocols

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.

EHS Journal Publishes Detailed Article on Elm iPad Trials

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.

In Tampa, a Mining Company Shutdown Highlights Business Interruption Risk from Environmental Issues

In Tampa Bay, an all-to-real demonstration is playing out of the trickle-down economic impact of a company operation being shut down for environmental reasons.  The Tampa Bay Business Journal reported this story.

The Mosaic Co. is a publicly-traded company with over $6billion in annual revenue reported last fiscal year.  Mosaic mines phosphate ore.  The company has been mining in Polk County since 1995 and recently filed for an expansion of operations to access reserves in Hardee County.  These ore reserves represent about 10 years of active mining operations.

The Sierra Club, along with other NGOs challenged the issuance of a federal permit that would allow Mosaic to expand, alleging that the expanded operations would cause environmental damage to the headwaters of the Peace River and other streams that drain into the Charlotte Harbor estuary.

On July 30, in response to the challenge

U.S. District Judge Henry Lee Adams Jr. in Jacksonville issued a preliminary injunction against the expansion, saying the Army Corps had failed to adequately explore alternative plans that would cause less environmental damage to the area.

The article reports that, if the Mosaic expansion does not move forward, the economic impact would be dramatic.

At least 18 companies that do business with Mosaic would be out at minimum of $80 million in combined annual revenue, and about 400 of their employees would lose their jobs, in addition to the 221 Mosaic workers who would be laid off …

“If Mosaic is prohibited from further mining, it will mean that Bul-Hed Corporation would cease to exist sometime in the near future,” Ronnie Hedrick, president, said in a court filing.

Mosaic has estimated it would lose $250 million to $300 million in operating earnings in a worst-case scenario.  In its fiscal year ended May 31, Mosaic had earnings of $1.75 billion before interest, taxes, depreciation and amortization on net sales of $6.76 billion.

Business Interruption Planning

The company’s most recent 10-Q (Item 1A – Risk Factors), filed April 1, 2010, did  disclose this potential risk:

Expansion of our operations also is predicated upon securing the necessary environmental or other permits or approvals. Over the next several years, we and our subsidiaries will be continuing our efforts to obtain permits in support of our anticipated Florida mining operations at certain of our properties. In Florida, local community participation has become an important factor in the permitting process for mining companies, and various local counties and other parties in Florida have in the past and continue to file lawsuits challenging the issuance of some of the permits we require. In fiscal 2009 environmental groups for the first time filed a lawsuit in federal court against the U.S. Army Corps of Engineers with respect to its issuance of a federal wetlands permit and similar lawsuits could be brought in the future. A denial of, or delay in issuing, these permits or the issuance of permits with cost-prohibitive conditions could prevent us from mining at these properties and thereby have a material adverse effect on our business, financial condition or results of operations.

Even so, how should the company – and its business partners – respond to such a risk?  And did business partners understand, assess and plan for such a contingency?  In many discussions we have had with clients about potential shut downs, it is common for companies to plan production volume shifts across other operating locations to make up for the lost volume and continue operating.  In Mosaic’s case, however, the article states:

Although Mosaic has four other mines in Florida, their output would not offset the impact of a shutdown at South Fort Meade, the company said.

Even where a company has the physical capacity at other locations to make up for lost production at one plant, environmental restrictions may not allow timely production increases at others.  Wastewater and air permits typically contain conditions limiting production.  These limits can take various forms:

• Direct limits.  For example, plant operating hours or volume; emissions limits for production equipment or material use; wastewater flow or contaminant concentration limits.
• Indirect restrictions.  For example, fuel use or emissions limits on supporting equipment such as generators or boilers; wastewater treatment capacity/retention time for adequate treatment.

Suppliers, contractors and vendors may attempt to recover losses from Mosaic through the contractual obligations in place between the parties.  However, in this case, Mosaic has notified at least some of their business partners that this is a “force majeure” event – an extraordinary circumstance beyond their control – which releases Mosiac from contractual obligations.

Has your company evaluated/assessed the myriad business continuity risks associated with environmental matters in your supply chain?  And what contingency plans do you have in place to protect yourself?