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Encouraging Self-Auditing Within the Pork Industry: The Nationwide Clean Water Act Enforcement Agreement for Agriculture's First Industry-Wide Environmental Auditing Program

July 1999

Citation: ELR 10395

Author: Richard E. Schwartz, Steven P. Quarles, and Ellen B. Steen

Editors' Summary: Late last year, EPA and the National Pork Producers Council (NPPC) announced that they had developed a compliance assurance program (CAP) under which U.S. pork producers can reduce their penalties for FWPCA violations that they report and correct as part of a comprehensive environmental auditing program. This Dialogue examines the CAP and the terms of the agreement that pork producers may sign to register for the CAP. The Dialogue begins by describing the context in which the CAP was developed. It then discusses the terms of the CAP agreement and analyzes some of the key issues addressed during the negotiations between EPA and the NPPC. The Dialogue concludes with an examination of how the CAP approach could benefit other industries.

Richard Schwartz and Steven Quarles are partners, and Ellen Steen is an associate, at Crowell & Moring LLP in Washington, D.C. The authors negotiated on behalf of the National Pork Producers Council the Compliance Assurance Program discussed in this Dialogue.