Colleges & Universities in New England

Audit Initiative

In July 2001, EPA New England launched an Audit Initiative to encourage colleges and universities to voluntarily discover, disclose, and correct violations of environmental requirements. Under the Initiative, EPA eliminated or substantially reduced fines for violations that were disclosed or corrected during the audit. Participants were also granted the added incentive of a low EPA inspection priority status for a set period of time.

More than half of the 331 college and university facilities in New England participated:

Connecticut	40
Maine	22
Massachusetts	72
New Hampshire	2
Rhode Island	7
Vermont	28

The majority of violations reported through the Audit Initiative involved violations of the Resource Conservation Recovery Act (RCRA), the Clean Water Act (CWA) and its Spill Prevention Control and Countermeasures (SPCC) requirements, and the Emergency Planning Community Right-to-Know Act (EPCRA). To view a list of “common violations” identified during the Audit Initiative and EPA inspections.

In 2003, Industrial Economics, Inc. and the Harvard University Kennedy School of Government performed independent evaluations of the Audit Initiative. Findings included:

• 75% of participants took short-term corrective actions to come into compliance
• 96% of participants plan to implement long-term solutions to their environmental compliance problems rather than resort to temporary fixes. Many C/Us commented that part of their long-term solution will be the implementation of an Environmental Management System (EMS).
• 81% of participants plan to continue conducting audits
• audit results gave Environmental Health and Safety staff the leverage to successfully obtain increased funding for environmental compliance
• EPA’s outreach efforts (workshops, website, list of common violations) were considered highly effective by the sector

To learn more about the Evaluation and view the complete reports.

Although the EPA New England College and University Audit Initiative is now closed, the benefits offered by the Audit Policy remain available. We continue to encourage all colleges and universities to conduct self-audits and, in the case of institutions previously participating in the Audit Initiative, to continue to perform them. The EPA Audit Policy is entitled "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, Notice, 65 F.R. 19618, April 11, 2000" (PDF) (11 pp., 321 KB, about PDF). Under the Policy, your decision to conduct an audit and self-disclose violations is purely voluntary.

• Audit Policy and Guidance
• July 2005 letter to college and university administrators about the outcome of the New England Audit Initiative for Colleges and Universities (PDF) (2 pp., 454 KB, about PDF)

July 2005 letter to colleges and universities in New England from Robert Varney, Regional Administrator, EPA New England (PDF) (2 pp., 454 KB, about PDF)