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Manufactuerer's Assistance & Strategic Planning

Environmental Compliance, Inc. (ECI) personnel have been providing manufacturer's assistance & strategic planning to private companies for over 20 years regarding China. ECI will assist your company in the following areas:

  • Working with the governments of China, virtually all industry/companies are owned by the government, lack of transparency favors all things in China and ECI personnel (both here in the US and in China) are very knowledgeable of this issue and how to deal with all situations;

  • Negotiations, ECI fully understands that nothing in China is what it seems and has assisted numerous clients with in depth investigations in China;

  • Plant design, permitting, and construction; ECI has experienced personnel to successfully construct and provide manufacturing operations support to our clients;

  • Food Safety and Security Services;
  • Business development and management, project management, and assistance with products and equipment introduction and installation in China;

  • Monitoring the quality of products produced in China and making sure that your manufacturing facility in China does not compete with you or introduce products into your distribution chain;

  • Human Resource Management (HRM), hiring the correct personnel is a key to making any organization work. ECI has significant experience in China with HRM activities;

  • Marketing, ECI has significant marketing and sales experience in China and has set up manufactures representative networks for US based companies;

ECI has assembled a team of experts specializing in terrorism and emergency response, bio-safety & bio-security, as well as risk management and security and vulnerability assessments for the food & beverage processing industry. New regulations contained under the Department of Homeland Security Chemical Facility Anti-Terrorism Regulations 6 CFR 27 was issued in December of 2006. The Interim Final Rule was published on April 9, 2007-Federal Register: April 9, 2007 (Volume 72, Number 67), Rules and Regulations, Page 17687-17745. The regulation, with the exception of Appendix A, will go into effect on June 8, 2007. ECI has personnel to address all compliance requirements of this new and important regulation.

In addition, ECI has assembled a team to provide supply chain food safety and security from The People’s Republic of China (mainland China). ECI has personnel in numerous cities in China with Science and Food Technology experience including Hazard Analysis Critical Control Points (HACCP) regulations/guidance. These personnel coupled with experienced investigators and due diligence experts allow ECI to thoroughly track/investigate the supply chain for human and pet consumption products or raw materials used in US food/beverage processing.

ECI provided strategic planning for a formaldehyde manufacturer in Guangdong province that supplied a State owned particleboard manufacturer with the “Glue” to hold the wood chips together to form the particleboard. The formaldehyde manufacturing facility was owned by a United States based specialty chemical manufacturer and only supplied this one State owned particleboard manufacturer with no other outlet for their formaldehyde product. ECI directed the formaldehyde manufacturer to joint venture with a German particleboard manufacturer in China that would sell their product direct to the China based customers. ECI’s recommendation for “Forward Vertical Integration” was a result of ECI’s substantial experience in China and the understanding that the most successful international companies that have ventured into China have controlled their own destiny through vertical integration and control of their products through distribution to the end user, the Chinese people.

ECI completed a Chromium Encapsulation Project in the People’s Republic of China- Project No. 2002-30084A for the U.S. Trade and Development Agency (US TDA). ECI reviewed the technical, economical, financial, regulatory, and political aspects of applying a United States based chromium encapsulation technology/reagent to over 20 sites throughout China. ECI received praise and the highest marks on the Evaluation of Advisory and Assistance Procurement form filed by the U.S. Trade and Development Agency for the work performed on this project. In addition, the U.S. Trade and Development Agency wrote: “ The report took a very difficult subject and provided a clear recommendation to TDA based on the information provided. The contractor is very knowledgeable about China’s environmental issues”. ECI supplied the US based manufacturer with numerous suggestions of how to successfully implement their product in China. One major recommendation was not for use to encapsulate the chromium in the spent ore piles located throughout China as the manufacturer had originally thought, but to use the product to reduce chromium in wastewater discharges from municipality operated wastewater treatment plants in China. The US TDA agreed with ECI’s direction to this more open and funded market within China.

ECI assisted a US manufacturer design, construct, and staff a 54,000 square foot manufacturing facility located in Kushan, near Shanghai. ECI provided engineering support for the design institute designing the building and designing the wastewater treatment system and piping to meet stringent (more so than in the US) discharge standards. ECI provided construction management to protect the US client and insure the building is properly constructed using approved materials and construction techniques that are cost effective. Prior to ECI’s involvement the US based manufacturer had hired a number of design and construction companies to implement their plans. ECI recommended using other companies and worked closely with the US manufacturer to make certain the firing of the originally hired companies would not interfere with the construction process.  In China many of these companies are owned by the local authorities or by politically entrenched individuals (extremely non-transparent) and firing of these companies can bring a construction project to a very quick halt. ECI’s understanding of these issued allowed the construction project to continue on a schedule approved by the US based manufacturer. ECI provided assistance with staffing requirements including the General Manager, Operation Manager, and all supervisors and laborers. In addition, ECI assisted in the financial development for the newly established wholly owned foreign enterprise.

ECI has provided one of the top ten worldwide companies with acquisition expertise in Chengdu, People’s Republic of China where a fiber optic cable facility was sold to another multinational company based in the United States. ECI provided due diligence evaluation of the physical facility, evaluated on-going operations for compliance with appropriate corporate environmental policies and Chinese regulations, and provided solid/industrial waste disposal recommendations based on facility records and existing operations. Both the seller and the acquiring company were pleased by the report that was supplied in Chinese and English. ECI provided the aforementioned for other facilities located in Shanghai (clean room, optics assembly operation) and Wuhan (electronics assembly operation). ECI performed these aforementioned activities in Wuhan, Chengdu, and Shanghai for a $1.8 billion acquisition/merger for a United States based private client/manufacturer that is listed as one of the top 100 largest companies worldwide. In addition, ECI had numerous meetings and provided strategic planning at a large facility under construction in Pudong near Shanghai. The Pudong facility was the first of its kind in all of China where catalytic converter substrates for vehicles were to be manufactured.

ECI accompanied a CEO and technical support staff of a $50 million company to Hangzhou for the potential purchase of a local Chinese company. ECI personnel assembled in Hangzhou to provide investigation, negotiations, and translation support for the US based company. ECI’s personnel attended an evening banquet and the following day visited two (2) two manufacturing plant sites that were potentially for sale to the US based company. ECI’s investigative report indicated a number of potential issues including a problem that has cost a French company, Danone over $100 million as reported by the Wall Street Journal, see article dated June 8, 2007. As a result of ECI’s investigative report the CEO decided not to purchase or partner with the Hangzhou based company and avoiding the problems that Danone discovered more than one year after ECI delivered the investigative report to the CEO.

ECI provided business strategy development, negotiations, and translators for a US manufacturing company that will sell $2,000,000 in parts to a Chinese company. ECI supported this effort in Hefei with business strategist and translators.

ECI personnel led a multi-national team comprising staff from the United States, China and Germany in the performance of a Phase I environmental audit at the Beijing Glass Instrument Factory (BGIF), to support a proposed joint venture between BGIF and Schott Glaswerke. ECI personnel supported the Chinese client during numerous meetings with the Schott Glaswerke vice presidents in charge of legal counsel and Asian product development. The facility consisted of a coal gasification system that allowed the facility to generate coal gas for use in heating the glass melting furnaces. ECI personnel provided technical review of the coal gasification system and glass melting operations.

Food Safety and Security Services:

ECI and our personnel have been performing environmental & corporate due diligence, site & corporate investigations, permitting & licensing, design & construction management, and implementing risk management systems approach for numerous clients in China for 20 years. Specific to food and beverage processors, ECI personnel use the Operational Risk Management (ORM) Process recently developed by the US FDA Center for Food Safety and Applied Nutrition in response to food safety & security issues.

The ORM system approach uses the Hazard Analysis Critical Control Points (HACCP) while incorporating the US Department of Defense guidelines for food safety and security for military personnel against “Aggressors” (i.e., criminals, protesters, terrorists, subversives, and rogue or disgruntled insiders).

ECI uses the ORM system approach for China as this international/global approach works best and is more encompassing of the issues in China. The food chain (i.e., from farm to processor & transportation) in China differs significantly from that of the US resulting in critical control points that most Americans can not even imagine (i.e., use of human waste as fertilizer, significant chemical use, environmental conditions that significantly and adversely impact the safety of the food chain, regulations that are ineffective and rarely enforced, profit over food safety at a level rarely seen in the US, etc.). 

Since 1999 ECI has provided safety and security services to the food and beverage processors in the United States. Many of ECI’s clients are easily recognized household brand names that have earned their reputation as leaders in the food and beverage industry supplying safe and secure products for family and pet consumption.

ECI provides the following for the supply chain from China:

Task #1:              Identification of Potential Hazards

  • ECI provides on-site evaluation of potential food/beverage safety hazards for the supply chain leading to the United States. Many potential safety hazards are unique to China and US based companies are unaware of these potential safety threats. ECI personnel in China are very experienced in on-site evaluations that include but are not limited to potential cross contamination, tampering, cleanliness, product re-use (China’s no waste policies), chemical (i.e., pesticide/herbicide) use, and supply chain participants (not always obvious to the US purchaser).

Task #2:              Risk Assessment

  • ECI provides risk assessment for on-going operations, corporate purchases (raw material supplies or entire operating facilities), mergers & acquisitions, supply chains (including growing, storage, transportation, and processing operations), and end supplier operations.
  • ECI assesses the hazard probability (i.e., frequent, likely, occasional, seldom, and unlikely as defined by the ORM System approach). ECI personnel have extensive experience and understand this approach designed to identify frequency to compare against costs to prevent the risk.
  • ECI assesses the hazard severity to determine the potential impact on people, animals, and the mission for food/beverage safety and security. ECI personnel understand that severity needs to be identified for comparison to other risks.
  • ECI personnel assess hazard exposure by determining the level of exposure to the hazard and document it in the report provided to the US based company being supplied. Repeat exposure to a hazard increases the probability of a mishap occurring and these are identified in the report.

Task #3:              Analysis of Risk Control Measures

  • ECI personnel are very experienced in food/beverage safety and security risk control measures and developing least-cost alternatives for implementation. Risk control options such as rejecting the risk altogether, means to avoid risk or delay risk, risk transference, spreading risk over time or distances, risk compensation, and overall risk reduction should be included as risk control measures and least-cost alternative.
  • ECI incorporates proven order of precedence for addressing hazards and reducing the resultant risk. ECI provides plan/design for risk minimization, identifies and incorporates safety devices/systems, designs warning system devices, and develops procedures and training to support and promote food safety and security efforts.

Task #4:              Make Control Decisions

  • ECI in conjunction with the client will identify the decision makers that will implement the control measures identified in Task 3 above. ECI uses multi-disciplinary personnel, departments, and companies (stakeholders) all working as a team to accomplish this task. Decision makers may include ECI personnel that are on-site at various times/stages of the implementation and monitoring process to oversee the corrective measures, safety and security measures that are required to be implemented.

Task #5:              Implementation of Risk Controls

  • ECI works closely with all stakeholders including the client to implement the controls. ECI will work closely to execute the implementation of the protective measures: define the responsible parties, identify responsibilities, assign accountability and involvement. ECI and the client will identify different personnel to implement controls based on severity of safety and security risks.

Task #6:              Supervise, Monitor, and Review

  • ECI works closely with the client and stakeholders to effectively supervise the risk controls that were implemented in Task 5. ECI will provide on-site examination of the effectiveness of the risk controls and re-evaluation as the monitoring process continues. Monitoring may include food testing, on-site control measure implementation oversight, on-site re-evaluations, and reporting back to the client and stakeholders to confirm the effectiveness of control measures.

 

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