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Environmental self-audits

Internal Investigations of Environmental Crimes

The initiation of a government environmental criminal investigation or discovery of a serious compliance issue often triggers the need to conduct an internal investigation. The decision to conduct an internal investigation entails...

Quality Assurance in EHS Audits and Audit Programs: The New BEAC Standards

How does a chief executive officer (CEO) know when he or she certifies to the accuracy and completeness of the company's annual report, filed with the U.S. Securities and Exchange Commission (SEC), that all of the company's...

Cooperation With Government Agencies Under Environmental Audit Privilege/Immunity Laws, Rules, and Policies

This Article examines what the term "cooperation" means in major federal policies, state audit privilege/immunity laws, and state self-disclosure policies and rules in existence as of September 2003. In particular, this Article...

Voluntary Disclosure of Environmental Violations: Is Mea Culpa a Good Idea or a Bad Move?

You are in your office one afternoon when the phone rings. It's the vice president of environmental affairs for one of your clients. He tells you the company just discovered a major violation of an environmental law. The good news is...

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

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...

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

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...

National Conference of State Legislatures Study Finds That State Environmental Audit Laws Have No Impact on Company Self-Auditing and Disclosure of Violations

Editors' Summary: State audit privilege and immunity laws and audit policies have been championed as a way to encourage facilities to audit, or increase the auditing of, their compliance with environmental laws. A recent study by the...

EPA's Audit Policy and State Audit-Privilege Laws: Moving Beyond Command and Control?

The pursuit of environmental protection traditionally meant the imposition of command-and-control regulation and enforcement by federal and state environmental authorities. For at least 25 years, the protection of this country's air,...

Promise and Reality in the Enforcement of the Amended Clean Air Act Part II: Federal Enforceability and Environmental Auditing

Editors' Summary: This Article is the second in a two-part series that examines the promise and reality of Clean Air Act enforcement by reviewing four central enforcement issues: (1) the development of the "any credible evidence"...

Criminal Enforcement of Environmental Laws: Part III--From Investigation to Sentencing and Beyond

Editors' Summary: In this last of a three-part series, the authors provide a "how-to" guide for responding to an environmental criminal investigation and discuss the ramifications of an environmental criminal conviction. They first...