Prior to the November 1 closing of the reopened public comment period on SEC’s proposed conflict minerals regulations, several companies and individuals filed new or updated comments. Among the commenters are two organizations serving environmental, health and safety auditing practitioners. … Continue reading →
Last Friday, the US State Department issued its statement on conflict minerals supply chain traceability. Section 1502 of the Dodd-Frank Act requires that the State Department – in parallel with the SEC – provide guidance on due diligence activities to companies. The Department stated that … it is critical that companies begin now to perform meaningful due diligence with respect to conflict minerals. To this end, companies should begin immediately to structure their supply chain relationships in a responsible and productive manner to encourage legitimate, conflict-free trade, including conflict-free minerals sourced from the DRC and the Great Lakes region. Doing so will facilitate useful disclosures under Section 1502, as well as effective responses to any discovery of benefit to armed groups. The Department specifically endorses the guidance issued by the Organization for Economic Cooperation and Development (OECD) and encourages companies to draw upon this guidance as they establish their due diligence practices. We encourage companies, whether or not they are subject to the Section 1502 disclosure requirement, that are within the supply chain of these minerals to exercise due diligence based on the OECD guidance and framework as a means of responding to requests from subject suppliers and customers. Companies
Read more →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
Read more →Updated March 2012: See our most recent announcement. 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
Read more →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.
Read more →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.
Read more →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 →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.
Read more →The Elm Group International, LLC is accepting entries for a drawing to win an environmental compliance audit priced at $1.00 fixed rate for labor fees. The contest winner gets 5 consecutive days of one Elm staff member’s time to conduct an environmental compliance audit in the U.S – for $1.00 in labor cost. The rules and limitations (posted in the entry form) set forth the details of this offer. Patrick Doyle, founder of Elm: “Elm has been financially successful ever since its founding in 2003. Even in the midst of the worst global economic collapse since the 1930s, Elm posted record revenues in 2009. In light of that, we wanted to have some fun in 2010. Part of that was investing in new technology such as the iPad, which proved to be very successful in the field. This give-away is another opportunity for us to have fun, while also providing real benefit to the winner.” “There is a bit of a thrill in this for us,” said Lawrence Heim of Elm’s Georgia operations. “We certainly don’t know what type of company or site will win and I have no idea where I will be traveling to for this assignment.” “I
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