How Do I Make a Voluntary Disclosure Under EPA's Audit Policy?
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To date, 76 colleges and universities in New
York, New Jersey and Puerto Rico have come forward to disclose
more than 800 violations to EPA. Most of them have been granted
a 100% waiver of penalties totaling more than $2.4 million.
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Once a violation has been discovered, a company has 21 days from the time of that discovery to disclose the violation to EPA. Companies should make the disclosure to the EPA Regional Office where the affected facility is located. A list of Audit Policy contacts in EPA regions other than Region 2 is available online. Voluntary self-disclosures for violations which have occurred in U.S. EPA's Region 2 (New York, New Jersey, Puerto Rico, and the U.S. Virgin Islands) should be sent or faxed to Region 2's Audit Policy Coordinator, whose address is given below. In the event of violations affecting more than one Region, companies should contact Leslie Jones, EPA's National Audit Policy Coordinator, at (202) 564-5123.
Self-disclosures in Region 2 should be sent to:
Audit Policy Coordinator
U.S. Environmental Protection Agency, Region 2
290 Broadway
21st Floor (DECA/CAPSB)
New York, NY 10007-1866
Phone: (212) 637-4008
Email: gorman.john@epa.gov
The disclosure should identify the means of discovery, type of violation,
facility location, and how it meets the conditions of the policy. EPA
encourages companies to review our
Sample
Disclosure Follow-Up Letter and the Self-Disclosure Questionnaire
in Attachment A of that letter to get a sense of the type of information
needed about the violation(s) being disclosed in order to process the
submission.
Before self-disclosing, you may wish to consult one or more of U.S. EPA's policies which deal with self-disclosures and incentives for compliance.
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