Tag Archives: environmental audit

Now Available – Summary Review/Comparison of Conflict Mineral Supply Chain Traceability Audit Programs

Elm has developed a short summary review of conflict minerals audit programs based on our industry-leading first-hand experience conducting these audits, and leveraging our extensive international senior-level health, safety and environmental (HSE) auditing expertise.

If you are interested in receiving our summary document, please send us an email (lheim@elmgroup.com) or feel free to call us.  We look forward to hearing from you soon.

 

Elm’s Auditing Expertise Extends to “Conflict Mineral” Supply Chain Traceability

The US Securities and Exchange Commission (SEC) gave 2010 an interesting send-off by publishing its proposed regulations on Conflict Minerals Reporting and supply chain traceability on December 15, 2010.  The requirements will impact many industries and companies (U.S. and foreign) in various ways.  The Law itself, the proposed regulations and the Organization for Economic Cooperation and Development (OECD) Conflict Minerals Due Diligence framework create expectations and ambiguities concerning supply chain traceability/auditing programs.

Between August and December, The Elm Consulting Group International, LLC completed one of the first third-party audit/traceability engagements in response to The Conflict Minerals Law and OECD program.  The audits resulted in the first “Conflict-Free Smelter” designation in the United States under the audit program for tantalum.

As a result of that success, we are launching a broadened Conflict Minerals Traceability Auditing service to include tin, tungsten and gold.

To assist clients and others, Elm has developed a short summary review of conflict minerals audit programs – based on our industry-leading first-hand experience conducting these audits, and leveraging our extensive international senior-level health, safety and environmental (HSE) auditing expertise.

If you are interested in receiving our summary document, please contact us.

 

Founded in 2001, The Elm Consulting Group International, LLC is a specialty health, safety, environmental and sustainability management services firm with 5 offices in the United States, as well as offices in Mexico, Argentina, New Zealand, Indonesia, an exclusive joint venture in China and a network of over 100 hand-selected affiliates in 22 other countries.  To maintain our independence as auditors, our services are focused on audit program development and execution, and we maintain various third-party HSE auditor certifications in the US and abroad.

 

The Elm Group International, LLC Gives Away an Environmental Audit

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 am not sure if anything like this has been done before.  We had some initial trepidation about the idea, but our enthusiasm and excitement won over,” according to Robert Bray of Elm’s California operations, who just completed his tenure as the President of The Auditing Roundtable.  “And we have the chance to help a company with their environmental management costs.  Everyone wins.”

Click here to complete the entry form.

A Question from Your Company’s President/CEO: How Come the Audit Didn’t Find That?

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 of “Black Swan” events.
  • Generally a two-dimensional framework is effective to communicate risk likelihood and impact separately.
  • Create a risk profile assuming controls will fail.  Remember that at this point, you are identifying a “gross risk profile”.  Effectiveness of controls should be evaluated in a separate step.
  • Evaluate the risk profile for auditable topics and elements.  Once the appropriate topics are identified, audit protocols can be developed.  However, these protocols are typically beyond the scope with which traditional EHSS auditors are comfortable.
  • Develop guidelines for appropriate corrective actions.  For example, a risk that is high impact/low likelihood may be best treated with a financial solution to reduce the economic impact of a rare event.  A management system approach to such a risk may not prove relevant or effective.

These ideas may help provide some guidance on how to move ahead, reduce real business risk and generate demonstrable economic value.