Recently, Elm posted a piece discussing comments from Kevin Parker, the CEO of Deutsche Asset Management, an investment firm with three-fourths of US$1 trillion under management. We expanded that original post for EHS Journal, who just published it. The expanded … Continue reading →
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
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 →. FOR AN UPDATE ON SEC’S DELAY OF THE FINAL RULE, CLICK HERE. As veterans of regulatory research, we are accustomed to spending hours poring over a plethora of governmental regulations, background documents, guidance and other reports. Our work with conflict minerals supply chain traceability and SEC’s regulations has been no different. In addition to having completed such audits, we have read and re-read the proposed SEC regulation and its preamble; the OECD Due Diligence Guidance for Responsible Supply Chains of Materials from Conflict-Affected and High Risk Areas, and the Supplement on Tin, Tantalum and Tungsten; the ISO 19011 standard; comments submitted to the SEC on the proposed regulation (approximately 700 total comments were submitted, of which 433 were standard form letters. Of the remaining 270, approximately 75% provide substantive content); hundreds of relevant media reports, legal advisories and NGO documents; various auditor standards under SEC, including Government Accounting Office Government Accounting Standards GAO-07-731G, AICPA Statements on Standards for Attestation Engagements (SSAEs); and industry commentary and alerts on the topic. Yesterday, we completed an analysis of the 263-page report from the Boston Consulting Group (BCG) titled US Securities and Exchange Commission Organizational Study and ReformMarch 10, 2011 to see what
Read more →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
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 →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
Read more →Elm has completed its initial field trail of the iPad for EHS auditing. Lawrence Heim of Elm’s Georgia office: In our week-long test of the iPad in an actual client audit setting, we used many of the features available in our selected data collection application. There were other relevant features that we did not use this time, but expect to in the future. To sum it up, the iPad and our selected application performed flawlessly. Data capture – over 50 pages of handwritten notes in this case – was efficient and error-free. We were able to create charts, tables and diagrams, as well as use a “highlighter pen” feature. The user-defined data tagging function worked extremely well to quickly identify matters needing further information or clarification. That feature also allowed quick, easy access to – and certainty in locating – findings in the notes. Data tags clearly indicated finding summary information for further convenience. Exporting the notes was rapid and seamless. The resulting file can be viewed/emailed to the client in PDF form as well as other formats if needed. I believe that our use of the iPad created a time efficiency of between 15% – 20% on this particular field
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