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 →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 →Today The Elm Consulting Group International, LLC announced that it is testing out the iPad and certain applications for use in EHS audits. Elm supports many clients with EHS audit processes, so we must be flexible in audit approaches. Some clients have internally-designed audit tools that Elm uses in those instances. Other companies have automated reporting, but are not confined in their data collection processes. Our iPad use is likely to be of most benefit to those clients who do not have an existing computer-based EHS audit protocol/risk assessment systems. Rob Bray, Managing Director in Elm’s California office: We are optimistic that the data capture technologies in the iPad’s small and unique package will prove beneficial in the field. These technologies include: the ability to easily and quickly scan documents and annotate within those documents; voice note capture and automated transcription; handwriting capture and transcription; advanced note-taking applications; and where appropriate, photo capture and annotation. Elm expects to utilize all of these features to manage, organize and consolidate audit/assessment data. Certain applications will allow almost immediate access to specific information or notes that support each audit finding. Finally, all data gathered – including auditor notes and even recorded interviews –
Read more →Those of us who have been in EHS auditing for awhile have faced this question, either as internal corporate staff or as an outside auditor. You know the situation – an EHS event occurs at a site, it gets reported up the management chain and the questions (and possible finger pointing) begin. How could we have let this happen? How come we didn’t know about this sooner? What did the last audit find? And finally….. Why wasn’t it found or addressed in the audit? Most EHSS audit programs were built to address compliance or management systems conformance. Today, companies are beginning to approach these questions in a constructive manner, looking to develop risk-based EHSS audit frameworks. We at Elm are frequently asked how to incorporate the concept of “risk” into audit programs. For those wondering where to start, here are a few tips: Use existing risk benchmarks within the company. There is no need for EHSS risks to use separate definitions. Actively and aggressively coordinate with all aspects of the company. The business impacts of EHSS exposures are relevant to a surprising number of functions and actitivities. Conduct a thorough EHSS risk assessment. During this process, encourage and embrace discussions
Read more →Our last entry discussed the concept of “Black Swan” events, a term created by noted author Nassim Nicholas Taleb to describe an event that is (a) so low in probablility that it is unforeseeable and (b) so catastrophic in impact that it changes history. Certainly, risk assessments are predictive in nature and no one can predict the future with complete certainty. But in our view, one of the best tools available for risk assessments is an open mind. This can be a challenge in the EHSS world as we generally have engineering and other technical backgrounds. We have been trained to seek absolutes and eliminate uncertainties. At Elm, we believe that involving external support helps to identify and explore events (and their related exposures) that are relevant but get “technically rationalized” by internal staff. With the BP oil spill and the December 2008 Kingston, Tennessee coal ash pond failure, we began thinking about some of the Black Swan events discussed with clients in the past. Below are a handful of EHSS Black Swan risk events that we have discussed with clients over the past years – and some that are currently on our mind. Radical change in EPA’s regulation of coal
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 →Today Reuter’s reported that President Obama is ordering the Mine Safety and Health Administration (MSHA) to step up safety inspections and enforcement of mines. This action comes as the Administration’s response to the Massey coal mine explosion in West Virginia last week that killed 29 miners.
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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