Earlier this year, the US Department of Justice (DOJ) Fraud Section issued additional enforcement guidelines to US Attorneys, entitled “Evaluation of Corporate Compliance Programs.” DOJ’s US Attorneys perform these evaluations to weigh whether and how severely an organization might be charged for illegal conduct by directors, officers, or other employees. But individuals may be committing crimes to further the organization’s goals (remember Volkswagen’s recent use of fraudulent means to defeat emission requirements), or for their own purposes despite organizational efforts. For readers in organizations that aren’t encouraging criminal behavior, these guidelines provide important guidance to the design (and implementation) of effective compliance programs.Read More
Audit, Compliance and Risk Blog
Every place on Earth has at least a little radioactivity. It is found in bodies, food (not just in industrially irradiated food), the ground, and in many consumer products. The sun and outer space are sources of radiation. Radioactive materials prevalent in nature, such as those present in soils and rock formations and in the water that comes into contact with them, are called naturally occurring radioactive materials, or NORM. NORM typically does not present a problem to human health or the environment, as the radiation levels are very small, and there is generally not an exposure pathway. However, NORM can become concentrated as the result of certain human activities that also expose people and the environment to radiation hazards. Over time, this collection of individual concentrations/exposures has come to be regarded as part of a single, larger, and more complex problem—radiation contamination—referred to as TENORM (tee-norm).
For more than 25 years, I’ve taught one of the core required courses in the Hazardous Materials Management Certificate program offered by University of California Santa Cruz Extension (UCSC-Ex). The program is intended to provide professionals with a solid foundation in the principles, regulations, and technologies required to manage hazardous materials and hazardous waste. In my course–the Regulatory Framework for Toxic and Hazardous Materials–I provide overviews of:Read More
The collective experience of 54 environmental, health, and safety (EHS) audit directors and managers from some of the world’s leading multinational companies provides valuable insights for companies of all sizes and audit-maturity levels in guiding EHS auditing activities. With the goal of promoting continuous improvement in EHS auditing effectiveness and practices, AECOM’s International Audit Protocol Consortium (IAPC) has published its Seventh Biennial Environmental, Health, and Safety Audit Practices Survey Report--a 123-page report presenting the results, analysis, and lessons learned from its membership in critical EHS areas of: Audit Scope versus Depth; Auditor Independence, Competency, and Training; Compliance Point versus Control Failures; Audit Program Metrics and Evaluations; and Stakeholder Value.Read More
Boards of directors are responsible for governing their corporations. Many boards divide their work among committees. Committees often include an “audit committee,” with responsibilities that may include:
Management of chemicals by your organization raises a host of environmental health and safety (EH&S) issues. Some of those issues are represented by legal and regulatory compliance requirements, others by formal but non-binding programs that range from company policies to ISO certifications. In response, organizations adopt and implement a wide variety of EH&S programs, including very broad ones (e.g., compliance with the Hazard Communication Standard) as well as very narrow ones (e.g., programs for managing entry into Confined Spaces). Organizations with sufficient resources and the will to organize themselves will create systematic programs to evaluate EH&S issues to ensure they’re addressed, and to design and coordinate programs in ways that do so effectively and efficiently. (In 2013-2014 I prepared a series of e-books that outlined EH&S regulatory requirements triggered by chemicals - click here to download).
Two and a half decades ago, I left my home in Austin, Texas, armed with a BS in Civil Engineering from the University of Texas at Austin with an emphasis in water resources and environmental pollution control, and moved out to Los Angeles, California. My job as a young engineer was to be part of the Los Angeles Department of Water and Powers (LADWP) Superfund Group, a team in charge of assessing and cleaning up four federal Superfund sites in the San Fernando Valley (SVF) of southern California. Having taken Environmental Engineering 101 (“dilution is NOT the solution to pollution”), as well as classes in waste and hazardous waste management, hydrogeology, and many others, I felt ready to tackle the Superfund world…but what was it really?
In December we saw in this space that a US Environmental Protection Agency inventory showed solid reductions in greenhouse gas (GHG) emissions in recent years. Now EPA has issued its annual Climate Protection Partnerships report, which contains more good news on the emissions front.
This is the second of a two-part discussion on the August 13, 2013, the Public Company Accounting Oversight Board (PCAOB) proposal that would result in two new auditing standards. In the first article, I discussed the proposed concept of “critical audit matters” or CAMs. In this article, I discuss the proposed requirements to disclose how long the auditor has been auditing the company and to provide some assurance on “other information” that a registrant must file in an annual filing with the Securities and Exchange Commission (SEC). I conclude this article with some summary thoughts.