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RE: Corporate Enviro Compliance Reporting and the SEC or Who's on first?



Excellent discussion. 
One area that I think that we are notably behind on in the US when compared
with Europe, is mercury switches in automobiles. As I understand it unlike
our European counterparts, our manufacturers have been slow to eliminate
these switches from US automobiles without the incentive of specific
legislation. Consequently, millions of salvage automobiles each year are
crushed and incinerated with these switches intact.  One gram (maybe less
than a drop of mercury) can corrupt the water quality of an entire small
lake.  It is disconcerting to know that mercury is even more toxic when
vaporized.  
Some may be intrigued to learn that the "Mad Hatter" character  in the book
"Alice in Wonderland" was supposedly named and depicted so, on the basis of
the then "suspected" effects of mercury treatment in the felt hat
manufacturing industry.
 
Deborah MacCormac
Florida Department of Environmental Protection
Central Districr Office  - Orlando
P2 Coordinator 
 
 
 

	-----Original Message----- 
	From: KIRK M Mills [mailto:kirk.mills@state.co.us] 
	Sent: Mon 15-Jul-02 5:43 PM 
	To: sumpter.richard@epamail.epa.gov;
donaldsutherland-iso14000@worldnet.att.net 
	Cc: p2tech@great-lakes.net; rp-cinet@igc.topica.com 
	Subject: Re: Corporate Enviro Compliance Reporting and the SEC
	
	

	Please note I am responding to what I believe are serious
	over-generalizations by Mr. Sutherland regarding environmental
	regulation in Europe and Asia. I am not commenting on his financial
	environmental reporting comments.
	
	I was an auditor for a Fortune 50 company in the mid-1990's and did
	audits over much of Europe in that time. Then (pre-European Union
[EU]),
	environmental regulations and enforcement varied considerably from
more
	stringent than the US (Germany, Scandanavian countries) to almost
Third
	World levels (parts of Italy, Spain, and Portugal). Some European
	countries were going well beyond the US, for example, in regulation
of
	PBT's (persistent, bio-accumulative,and toxic chemicals) and Extended
	Producer Responsibility (you make it, you deal with it at the end of
its
	useful life).
	
	I am not current on EU environmental regulation, but from a little
	surfing, it seems they are moving from general principles and broad
	generalities to more specific regulations like for diesel trucks and
	cars ( http://www.europarl.eu.int/factsheets/default_en.htm ). In the
	mean time, countries have maintained their own regulations and
	enforcement, which as I said earlier, covers a pretty broad spectrum.
	From a recent cycling trip to France (it was Great!), I know that
	enforcement of EU regulations is a big concern to many and that
already
	there are big backlogs of enforcement actions against countries who
are
	not implementing EU requirements.
	
	While I didn't have personal experience in Asia, I think Japan was
	pretty well regulated and things went down from there. Certainly,
	Japanese, US, and European firms were all guilty of environmental
abuses
	throughout the rest of Asia. Some Asian countries were starting to
	require new facilities to meet emission limits comparable to US
	standards. Some had adopted US or European standards chapter and
verse,
	but enforcement was inconsistent.
	
	Again, I think it is a serious over-generalization to say US firms
	meeting US standards are greener than European or Asian firms.
	
	I will agree that the US leads the world in litigious enforcement.
	However, I am not sure that this sets as meaningful a benchmark for
	environmental performance as Mr. Sutherland suggests. In European
	countries, there is much more of a feeling "we are all in this
together"
	and government regulators and companies are able to reach agreements
in
	a more pragmatic and efficient way than in the US. I'm sure at times
	this process has been abused by kick-backs and political pressure,
etc.
	(like in the US), but it still seemed pretty effective. Someone from
	Europe or with more European experience would have more insight into
	this process.
	
	The one thing that was really different was level of public access
and
	transparency. In Germany, for example, one company in an industrial
area
	had created a serious groundwater plume. Our facility could only find
	out about the groundwater under its own property and the whole
picture
	was only known by the government and the facility that started the
	plume. In the US, pretty much all that information would be available
to
	the public. I think the level of public access to environmental
	information in the US helps to prevent abuses and keep everyone
honest.
	
	I would hope that someone with more recent information or more
in-depth
	international experience could weigh in on this. I would also hope
that
	we in the US do not feel we can rest on our laurels while the rest of
	the world catches up. We all have much work to do to reach
sustainable
	levels of resource, toxics, and energy use.
	
	
	
	
	
	
	
	Kirk Mills
	Pollution Prevention Program
	Colorado Department of Public Health
	     and Environment
	4300 Cherry Creek Drive So.
	Denver, Co  80246-1530
	Ph: (303) 692-2977
	Fax: (303) 782-4969
	Email: kirk.mills@state.co.us
	
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