Environmental Self-Auditing Explained, with Links to Current State Regulations

Environmental Auditing

Environmental auditing used to be conducted only by firms that were already in the environmental "fishbowl", such as large chemical manufacturers and hazardous waste disposal companies.  But recent changes in audit privilege, and the move toward environmental management systems, such as ISO14000 have resulted in changing attitudes and policies from government agencies.  The EPA has published policies to protect self-audits which you can download here.

Some reasons to consider  conducting an environmental self-audit are:

EPA Policies

The EPA Audit Policy, "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations", has been in effect since 1995. It safeguards human health and the environment by providing incentives for regulated entities to come into compliance with the federal environmental laws and regulations. The policy was designed to provide major incentives for regulated entities that voluntarily discover, promptly disclose, and expeditiously correct noncompliance, rendering formal EPA investigation and enforcement action unnecessary. The Audit Policy reflects the input of industry, trade associations, state environmental program practitioners, and public interest groups.

Disclosures are often preceded by consultations between EPA and the regulated entity, so that mutually acceptable disclosure details, and compliance and audit schedules can be discussed. If policy conditions are met, most penalties may be waived, and further civil or criminal prosecution may not be pursued.

Incentives for Self-Policing Under the Audit Policy

Conditions for Penalty Mitigation

Entities that satisfy the following conditions are eligible for Audit Policy benefits. Even if your entity fails to meet the first condition - systematic discovery - you can still be eligible for 75% penalty mitigation and for no recommendation for criminal violations.

Please refer to the Audit Policy, "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations", 65 FR 19,618 (April 11, 2000) (PDF, KB, 49 pages) for a more detailed discussion of eligibility and the application of the Audit Policy. Additional information about the Audit Policy and its use is available at the following:

Audit Policy

Audit Policy (PDF 88 KB) Policy on Incentives for Self-Policing, which provides potential penalty reductions for voluntary discovery and correction of environmental violations.

Audit Protocols

The Small Business Compliance Policy (PDF 43 KB) Effective date May 11, 2000. Sets out what makes a small business eligible for the elimination or reduction of penalties for violations that are voluntarily discovered, disclosed and corrected.

The Small Business Compliance Policy Fact Shee t: (PDF 75 KB) Summarizes the criteria in the Small Business Compliance Policy and provides EPA Regional contacts

Compliance Monitoring and Inspection Manuals

Federal Facilities

In addition to the foregoing 11 audit protocols, Federal agencies and facilities have available a "how-to" manual, the Environmental Audit Program Design Guidelines for Federal Agencies, Spring 1997 (PDF, 598 KB) , which offers guidance on designing and implementing environmental compliance auditing programs.

This page was updated on 16-Jul-2019