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EPA's Audit Policy Spells Success for Corporate Users, EPA, the Public, and Most Importantly, the Environment

November 1999

Citation: ELR 10705

Author: Nancy K. Stoner and Amanda A. Gibson

Editors' Summary: EPA's audit policy provides incentives for companies to develop environmental audit and compliance management systems to detect, disclose, and correct violations. When companies voluntarily discover environmental violations and disclose them to EPA, the Agency will waive or substantially reduce the applicable penalties. As part of EPA's proposal to revise this policy, the Agency conducted a survey to evaluate the policy's effectiveness. After outlining the basic tenets of the EPA audit policy, this Dialogue describes the results of the Agency's policy evaluation and explains the proposed revisions. The Dialogue then highlights how the audit policy is being integrated with the Agency's compliance and enforcement efforts. Last, the Dialogue illustrates some creative uses of the audit policy in various enforcement initiatives.

Ms. Stoner is the Director of the U.S. Environmental Protection Agency's (EPA's) Office of Planning and Policy Analysis (OPPA) within the Office of Enforcement and Compliance Assurance. Ms. Stoner served as an attorney in the Policy, Legislation, and Special Litigation Section of the Environment and Natural Resources Division of the U.S. Department of Justice from 1987 until fall 1996 when she joined EPA. Ms. Stoner obtained a B.A. from the University of Virginia in 1982 and a J.D. from Yale Law School in 1986.

Ms. Gibson is an attorney advisor in the OPPA. She received a J.D. from the George Washington University School of Law in 1991. Before joining EPA in late 1996, Ms. Gibson held jobs in private practice and clerked for U.S. Magistrate Judge Alan Kay of the U.S. District Court for the District of Columbia. The views expressed in this Dialogue are solely those of the authors and do not necessarily reflect those of EPA.

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