Tag Archives: tracking

Conflict Minerals, Meet US Sanctions

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Here comes another layer of “conflict minerals” restrictions.

President Obama last week set the stage for expanded sanctions against the Democratic Republic of the Congo and vicinity’s militia-ravaged region. A new Executive Order specifies that sanctions are called for against “individuals and groups tied to militias involved in the illicit trade of natural resources from the region” of the Democratic Republic of the Congo or DRC. If that criteria doesn’t include conflict minerals, what does?

Penalties to companies and individuals that fail to adhere to the expanding sanctions can include:

  1. Fines of at least $250,000
  2. Fines twice the amount of the underlying transaction
  3. Criminal penalties of up to $1,000,000
  4. Imprisonment for up to 20 years

Other conduct that will trigger future US sanctions:

  1. Actions or policies that threaten the peace, security, or stability of the DRC
  2. Actions or policies that undermine democratic processes or institutions in the region (DRC)
  3. The targeting of women and children with acts of violence (including killing, maiming, torture, and rape or other sexual violence), abduction, forced displacement, or attacks on schools, hospitals, religious sites, or locations where civilians are seeking refuge, or through conduct that would constitute a serious abuse or violation of human rights or a violation of international humanitarian law
  4. The use or recruitment of children by armed groups or armed forces
  5. Obstructing the distribution of, or access to, humanitarian assistance
  6. Attacks against United Nations missions, international security presences, or other peacekeeping operations.

Earlier this month, ahead of the Executive Order, US and United Nations Security Council added a Ugandan rebel group, the Allied Democratic Forces, to the sanction lists for “targeting children in situations of armed conflict through rape, killing, abduction and forced displacement.”

As far as conflict minerals go, this is yet another reason to know thy product ingredients and to continue tracking conflict minerals for compliance.

Thanks to many sources for these updates, for this one in particular thanks to Christopher T. McClure, Crowe Horwath LLP.

Green Chemistry: Sleeper Hit in Supply-Chain Compliance?

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These days, environmental regulations are changing the rules of the game in terms of how things are made, sourced and distributed in manufacturing and supply chains. The rules define the product and the process. More so than ever before.

Green Chemistry might be the sleeper key to compliance

Regulations make the brand? Regulations such as REACH, RoHS, “China RoHS,” “China REACH” and WEEE have huge impact on finished goods as they move through a supply network.  The impact of regulation is felt in all stages:

  1. design
  2. procurement
  3. storage
  4. manufacturing processes
  5. waste procedures and
  6. product distribution.

This is true in aerospace, automotive, packaging — but especially true in electronics, ever more so as the electronics industry becomes increasingly plastic-oriented.

We’re talking about products increasingly defined and designed by environmental interests.

Electronic paper. Of course, late last week the electronics industry became paper-based, or paper-esque shall we say (origami telephones, anyone?) when BBC London announced the debut of the paper cell phone.  Yes, you read that right. It’s a cell phone made of electronic paper. You could make an airplane out of it and try to get your friend’s attention — rather than call.

Increasingly we see more regulations and faster creation to disposal cycles. So how can the electronics industry cope?

E is for Electronics, Environmental, and EHS. Regulations are usually either strictly Environmental regulations or Environmental, Health & Safety (EHS).  Categories of regulations in electronics manufacturing and supply include:

  1. fire safety
  2. toxic substances
  3. product end-of-life
  4. air quality.

The last one, air quality, is a hot topic right now but is no more important than toxic chemicals, end-of-life or fire safety in electronics manufacturing.  Air quality typically comes down to Hazardous Air Pollutants (HAPs).  HAPs as a class cause serious environmental fall out.  HAPs include:

  1. sulfur dioxide
  2. nitrogen oxides
  3. volatile organic compounds (VOCs)
  4. hazardous air pollutants.

Green chemistry might be key. Action to reduce emissions can be done either by converting the waste itself or by using cleaner ingredients to begin with.  The latter is at the heart of green chemistry.  Green chemistry in fact addresses most environmental regulatory concerns:  the greener the chemistry, the fewer the environmental regulatory concerns.

To find out about Green Chemistry without the struggle of navigating the California.gov web site, try GC3 or Green Chemistry Council out of University of Massachusetts-Lowell.  Under the “Publications” section there are some helpful documents, including case studies by big companies like HP and Seagate who are seeking environmental regulatory compliance worldwide through greener chemistry.  Read up, go green, and as always: track, track, track your data.

Because it’s critical to be compliant, it becomes key to be green.  Remember:  there is no substitute for year-over-year tracking data for demonstrating to shareholders just how green you’ve been.

Green Chemistry image (top) courtesy of Actio Corporation Communications, used by permission.