Region 2 Audit Initiatives
Since 2000, EPA Region 2 has embarked upon several audit initiatives to encourage sectors with high non-compliance rates to voluntarily conduct compliance audits and disclose violations to EPA under our audit policy. Below you will find information on these initiatives as well as links to resources to help those sectors comply with environmental requirements and to conduct self-audits.
In early 2010, EPA Region 2 launched the Municipality Environmental Compliance Initiative with the goal of promoting greater compliance with environmental regulations. In February, 2010, EPA Region 2 will host a free two-day workshop for municipalities on “Regulatory Issues and Pollution Prevention Tactics.” This workshop will also explain EPA’s Audit Policy which urges municipalities to identify any violations in their operations and to voluntarily correct them. EPA is willing to waive gravity-based penalties for most violations that municipalities voluntarily disclose prior to EPA inspections. During the summer of 2009, EPA Region 2 filed individual complaints against six municipalities in Puerto Rico for improper stormwater management for a total of $291,177 in gravity based penalties (view press release). Stormwater is just one of several environmental issues and associated regulations municipalities need to be mindful of. Others include drinking water, waste management, and underground storage tanks.
In December 1999, EPA Region 2 sent a letter to all the colleges and universities in New York, New Jersey, Puerto Rico, and the Virgin Islands informing them of our intent to conduct inspections of academic institutions and encouraging them to voluntary conduct compliance audits of their campuses and to self-disclose any violations found to EPA under our Audit Policy. In response to this letter, we negotiated 22 audit agreements and received 157 voluntary disclosures covering 238 campuses, including the 64 campuses of the State University of New York which is the nation's largest university system. The most common violations involved managing hazardous waste properly. These disclosures resulted in the resolution of more than 2,785 violations and we estimate that more than 120,000 lbs/year of hazardous waste, 1.5 million gallons of oil and 80 class V wells are now being managed properly.
In the fall of 2005, EPA Region 2 embarked upon a compliance intiative to reduce the environmental footprint of the over 38,700 vehicle fleet maintenance facilities are located in New York, New Jersey, Puerto Rico, and the Virgin Islands. As part of this initiative, vehicle fleet maintenance facilities are being encouraged to take advantage of EPA's audit policy. Toward that goal, we have developed a vehicle fleet maintenance compliance checklist and model audit agreements for vehicle fleet maintenance facilities in New York and New Jersey. So far, we have negotiated 7 audit agreements, including an agreement with the Metropolitan Transportation Authority of New York City to complete comprehensive compliance audits of its bus and truck maintenance facilities by December of 2009. We have also received 34 voluntary disclosures from fleet maintenance facilities to date. As a result of these disclosures, more than 430 violations have been resolved and we have prevented more than 77,450 gallons of fuel and 610 gallons of hazardous waste from contaminating our environment.
Fleet maintenance facilities can find resources to help them comply with environmental regulations, implement environmental management sysetms, and reduce their overall environmental footprint by visiting EPA Region 2's Fleet Maintenance webpage.
On December 27, 2002, EPA Region 2 sent a letter to all 500 hospitals in New York, New Jersey, Puerto Rico, and Virgin Islands, including Veterans Administration hospitals informing them of our intent to undertake a compliance initiative in the healthcare sector and encouraging them to take advantage of EPA's audit policy. In response to this letter, we negotiated 42 audit agreements and received 196 voluntary disclosures covering 703 healthcare facilities. These disclosures resulted in the resolution of more than 4,000 violations and we estimate that more than 758,000 lbs/year of hazardous waste, at least 3 million gallons of oil, and almost 50,000 pounds of ozone depleting refrigerants are now being properly managed. In addition, the healthcare sector in Region 2 are now complying with the lead paint disclosure rules for more than 1800 residential units that they operate for their staff. Based on a survey conducted, the average cost of a compliance audit at a healthcare facility is approximately $10,200 and the average cost of returning to compliance based on audit findings was around $29,300. This average cost of compliance comes down to $16,600 if we exclude the two outliers in the survey that reported compliance costs in excess of $100,000. Given that the average penalty issued to hospitals that do not take advantage of EPA's audit policy is over $216,000, conducting self-audits makes not just environmental but also economic sense!
Healthcare facilities can find resources to help them comply with environmental regulations, reduce their environmental footprint, implement environmental management systems, and conduct environmental audits by visiting EPA Region 2's Healthcare website.
In 2007, EPA Region 2 began a compliance initiative to improve the environmental compliance rate of local governments' Department of Public Work's (DPW) facilities in New York and New Jersey. As part of this compliance initiative, we sent letters to almost 1200 municipalities encouraging them to perform environmental audits of their DPW facilities and to self-disclose these violations under EPA's audit policy. EPA Region 1 has developed a compliance checklist and list of common violations for public works facilties to help them comply with federal environmental, fire, and health and safety regulations which we encourage Region 2 public works facilities to take advantage of. So far, we have negotiated an audit agreement with the Onondaga County DPW and have received 8 voluntary disclosures. As a result of these disclosures, more than 36 violations have been resolved and we have prevented more than 47,000 gallons of fuel and 165 gallons of hazardous waste from contaminating our environment.
Local Governments can find resources to help them comply with environmental regulations, implement environmental management sysetms, and reduce their overall environmental footprint by visiting the local government environmental assistance network.