UPDATE: To help keep clients and others informed, we have added new insights and commentary based on further discussions with a variety of stakeholders. Our review of the final SEC regulation on conflict minerals is now available. While we strive to be first in presenting you important information, this time we chose a different path. In the days since the rule was adopted, we have had many discussions with clients, other companies, legal authorities, the SEC directly and others who raised a variety of points, preliminary interpretations and questions. Along with the technical substance of this complex ruling, our review also incorporates a number of unique insights from these discussions that are not reflected in other analyses. We have also included guidance on what companies should be doing in the next 12 months to prepare for the first reporting deadline and customer demands. We are using a stunning new presentation format (prezi) that is more effective than standard formats at communicating information/context and emphasizing key points. Prezi requires no new software or downloads and is easy to use: Full screen mode provides the optimum viewing experience. Click on the full screen icon near the lower right hand corner of the viewer. Navigate manually through
Read more →Greetings. This blog was newly launched on February 11, 2010 and we plan to build it over time. We hope this will become a useful source of information and dialog for those interested in – and actually using – the … Continue reading →
Greetings. This blog was newly launched on February 11, 2010 and we plan to build it over time. We hope this will become a useful source of information and dialog for those interested in – and actually using – the … Continue reading →
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
Read more →OSHA has released the directive concerning its Severe Violator Enforcement Program (SVEP). It can be read here.
Read more →The law firm of Morgan, Lewis & Bockius LLP has published details about the upcoming OSHA Severe Violator Enforcement Program (SVEP). The SVEP has been in development for more than a year, but Morgan Lewis indicated that a 27-page draft Directive was sent from OSHA to state officials in early April. Highlights from the Morgan Lewis review: According to the draft Directive, the SVEP will “focus increased enforcement attention on significant hazards and violations” by concentrating on employers that have demonstrated “indifference” to workplace safety obligations through willful, repeated, or failure-to abate-violations in four areas: (1) fatality or catastrophe situations; (2) industries that expose employee to the most severe hazards, including those identified in the draft Directive as “High-Emphasis Hazards”; (3) industries that expose employees to the potential release of highly hazardous chemicals; and (4) egregious enforcement actions. Once an employer is selected for the SVEP, OSHA will undertake a number of enforcement steps including enhanced follow-up inspections as well as inspections at other worksites of that same employer, potentially on a nationwide basis… OSHA will consider any inspection that meets one or more of the following criteria as a candidate for the SVEP: Fatality/Catastrophic Criteria. A fatality/catastrophe inspection in
Read more →The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) today announced it is issuing $87,430,000 in proposed penalties to BP Products North America Inc. for the company’s failure to correct potential hazards faced by employees. The fine is the largest in OSHA’s history. The prior largest total penalty, $21 million, was issued in 2005, also against BP. BP entered into a settlement agreement with OSHA in September 2005, under which the company agreed to corrective actions to eliminate potential hazards similar to those that caused the 2005 tragedy. Today’s announcement comes at the conclusion of a six-month inspection by OSHA, designed to evaluate the extent to which BP has complied with its obligations under the 2005 agreement and OSHA standards. For noncompliance with the terms of the settlement agreement, the BP Texas City Refinery has been issued 270 “notifications of failure to abate” with fines totaling $56.7 million. Each notification represents a penalty of $7,000 times 30 days, the period that the conditions have remained unabated. OSHA also identified 439 new willful violations for failures to follow industry-accepted controls on the pressure relief safety systems and other process safety management violations with penalties totaling $30.7 million.
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