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Self Monitoring

SELF-MONITORING THROUGH ENVIRONMENTAL
COMPLIANCE AND MANAGEMENT AUDITING

EPA defines an environmental compliance audit as a systematic, documented, periodic, and objective self review of facility operations and practices related to meeting environmental compliance. Audits are a critical component of an agency’s ongoing environmental management program because they:

EPA policy encourages all Federal agencies to adopt auditing programs to achieve and maintain compliance. FFEO provides technical assistance to help Federal agencies design and initiate audit programs. The following sections discuss EPA’s audit policy, guidance documents, and the procedures for conducting an audit.

Reasons for Conducting Audits

As part of the Agency’s obligation under E.O. 12088, Federal Compliance with Pollution Control Standards, to provide technical advice to other Federal agencies, EPA issued the Environmental Auditing Policy Statement, 51 FR 25004 (July 9, 1986) and a Restatement of Policies Related to Environmental Auditing, 59 FR 8455 (July 28, 1994), which, among other topics, specifically address auditing at Federal facilities. These policies encourage all Federal agencies to develop auditing systems to ensure the adequacy of internal systems designed to achieve, maintain, and monitor compliance with environmental laws and regulations. Audit programs should be structured to identify environmental problems promptly and expeditiously develop schedules for corrective action.

Self Reporting

In December 1995, EPA issued an ambitious new auditing policy, Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations that establishes Federal agency incentives for self-auditing. These incentives include a penalty incentive for self-monitoring, disclosure, and correction. The goal of the Audit Policy is to encourage regulated entities to voluntarily discover, disclose, and correct violations of environmental requirements. Under the 1995 Audit Policy, EPA will not seek gravity-based penalties or recommend that criminal charges be brought for violations that are discovered through an environmental audit or a management system reflecting due diligence. The 1995 Audit Policy covers only violations that are promptly disclosed and corrected, provided that other important safeguards are met. These safeguards protect health and the environment by precluding penalty reductions for violations that cause serious environmental harm or may have presented an imminent and substantial endangerment, for example. Conditions that must be met for EPA not to seek or reuse gravity-based penalties

In January 1997, EPA issued an update and guidance. The update, EPA Audit Policy Update (EPA 300-N-97-001), contains data indicating that the Audit Policy is having the desired effect. The guidance was issued to increase further the regulated community’s use of the 1995 policy by clarifying legal and policy issues that have arisen during implementation. In addition, on January 15, 1997, EPA issued the Audit Policy Interpretative Guidance (referred to as the Interpretative Guidance) to aid both the government and the regulated community in implementing the Audit Policy. The Interpretative Guidance uses a question and answer format to describe EPA’s position on numerous issues, including when repeat violations bar penalty mitigation and how EPA defines when a violation may have been discovered.

EPA has issued a Final revision of the Audit Policy which became effective May 11, 2000.

 

Guidance Documents and General Procedures for Conducting an Audit

EPA has issued two guidance documents to assist Federal agencies in developing effective auditing programs. The first, Environmental Audit Program Design Guidelines for Federal Agencies (EPA 300-B-96-011), also referred to as the Design Guidelines, was revised and issued by EPA to focus on the development of strong environmental auditing programs. Its companion document, Generic Protocol for Conducting Environmental Audits of Federal Facilities, Volumes I and II (EPA 300-B-96-012A and EPA 300-B-96-012B), was revised and issued in December 1996 and is referred to as the Generic Protocol. The purpose of the Design Guidelines is to provide information, criteria, and direction to Federal agencies that are designing audit programs. The Design Guidelines addresses concerns and considerations unique to Federal agencies, including organizational structures, chain of command issues, and planning and budgeting systems.

 

Additional Information

Mid-Atlantic Office of Enforcement
Compliance and Environmental Justice

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