er/to ANNOTATED BIBLIOGRAPHY ON ENVIRONMENTAL AUDITING September 1989 Eighth Edition Rev. 1 Prepared by: Todd C. Edwards Regulatory Innovations Staff Office of Policy, Planning and Evaluation U.S. Environmental Protection Agency 401 M Street, SW Washington, D.C. 20460 WASHINGTON, D.C. 20460 ------- The eighth edition of the bibliography on environmental auditing was prepared, by Todd c. Edwards, a summer intern working for the Regulatory Innovations Staff, Office of Policy, Planning and Evaluation, U.S. Environmental Protection Aaencv. Protection Agency. ------- This bibliography is meant to be a reference for individuals interested in environmental auditing, i.e., internal management systems for reviewing facility operations and practices to assess and verify compliance with environmental regulations and corporate policies. Environmental auditing, as an internal management tool, offers significant potential benefits for the environment, for industry, and for state and Federal agencies. It can better promote reduction in emissions, effluents, and solid wastes; assure corporate management that its facilities are in compliance with environmental requirements; and identify areas of potential cost savings while reducing strains on governmental enforcement programs. EPA has endorsed the concept of environmental auditing and is committed to encouraging its expanded use. This bibliography categorizes entries by subject area, based on each publication's major area of emphasis. Many publications cover several subject areas, but each publication is listed only once in this bibliography. The subject areas are: A. General Literature on Environmental Auditing B. Audit System Design and Methodology C. Confidentiality, Disclosure, and Other Legal Issues D. Industry Experience and Perspectives E. Pollution Prevention, Property Transfer & Envir. Impairment Liability F. Federal, State, and Local Perspectives and Activities Each entry includes the author and type of document as well as a brief abstract which summarizes the subject areas covered. The annotation should allow the reader to determine whether a publication covers subjects other than the one under which the publication is categorized in this bibliography. In addition, each entry provides the source from which the reader way obtain the document. Some of the iraterials listed may be obtained at no cost; however, others may have to be purchased from the source listed or obtained from a library. This bibliography does not exhaust the list of all of the published articles, papers, and reports on environmental auditing. Bather, it includes those publications providing unique perspectives and facts on environmental auditing or which seem of greatest potential use to organizations establishing auditing programs. Any comments or questions regarding this bibliography can be directed to the Environmental Auditing Project, Regulatory Innovations Staff (PM- 223), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460 or (202) 382-2726. Note; The materials included in this bibliography have not been endorsed by EPA or any other government entity. Any views or interpretations contained in these referenced documents are solely each author's and should not be attributed to EPA. -i- ------- AUIHQR INDEX Allison, Richard C. E-4 Andrews, Richard N. F-5 Arthur D, Little, Inc. A-4, Atkins, Patrick D-4 Barzotti, Joseph P. D-5 Basta, Michael F. D-7 Blakeslee, H. William B-3 Bleiweiss, Shell J. C-2 Brardwein, David D-2 Brookman, Gordon T. D-2 Cahill, Lawrence B. A-l, Capasso, Edward B-8 Case, David R. A-2 Christiff, Harold E-3 Cogen, Richard M. A-7, Cundall, Cheryl L. D-l Cutler, Robert W. D-3, Danzig, Allen J. F-l, DeMeester, J. M. C-l DiBerto, Maryanne A-2, Ellington, Andrew B-7 ENSR, Oorp. E-l Engineering-Science, Inc. F-2 Envir. Auditing Roundtable, Inc. A-5 A-10, A-12, B-l, D-l, D-2 E-3 E-2 D-6 F-2 B-3 -ii- ------- Environmental Law Institute, Inc. C-2, F-3 Executive Enterprises, Inc. B-2 Fahrenthold, Paul D. E-4 Fischer, Kenneth E. A-5 Ford, Mary Elizabeth A-7, E-2 Giannotti, David A. C-5 Gibson, Michael M. E-4 Goerth, Charles R. A-8 Goldsmith, Harold I D-4 Golob, Richard s. E-5 Grabowski, Theodore M. B-3 Greeno, J. Ladd A-2, B-3, B-7 Hall, Mark R. A-l Hall, Ridgway M. A-2 Harlow, Kirk C. E-4 Harrison, Lee A-3 Hedstrom, Gilbert S. A-2, A-6, B-3 Henz, Donald J. C-5 Holtzclaw, Gary D. E-4 ICF, Inc. E-l Institute of Envir. Auditing, Inc. A-2, A-3 Kalagnaman, Raraesh E-3 Kane, Raymond W. E-3 Keller, James R. D-5 Kent, Thomas D. A-5, C-l Kohm, Robert F. D-4 -iii- ------- Krouse, Richard S. A-7 Kuusinen, Tapio L. F-3 Libber, Jonathan . A-4 Marcus, Alfred A. B-5 Margolis, Joshua D. A-7 Mays, Richard C-3 Milvy, Paul E-5 Nadel, Mark V. B-5 National Wildlife Federation, Inc. A-9 Newton, J. E-2 Palmisano, John A-ll Pearse, William M. D-5 Pico, Richard F. D-4 Plaut, Jonathan E-2 Policy Planning & Evaluation,Inc. E-l, F-2 Price, Courtney M. F-l, F-3 Raffle, Bradley I. C-3 Reed, John W. A-9, A-10 Reed, Phillip D. C-4 Renella, John R. E-3 Rhodes, Ralph L. B-6 Robertson, Edwin B. Jr. D-5 Russell, David L. B-8 Samela, D.A. A-6 Scheid, Daniel C. . D-6 -iv- ------- Shields, Jacqueline Smith, Martin A. Spiegel, Stuart J. Springer Verlag, Inc. Stiehl, Fred Strutz, Dennis E. Trauth, darles TRC Environmental Consultants, Inc. Iruitt, Thomas U.S. Air Force U.S. Department of Energy U.S. Environmental Protection Agency Walker, Michael J. Weiss, Malcolm C. Willborn, Walter Williams, John K. Young, R. Victor E-4 A-8, D-7, F-4, F-5 D-l A-3 F-4 A-7 B-7 B-2 B-5 B-3 B-6 B-l, D-4, E-l, F-l, F-2 F-l A-ll, C-4 A-ll D-4 D-3 -v- ------- Title: "Environmental Auditing; An Effective Management Tool" Author: Mark R. Hall Doc. Type: Conference paper Abstract: An environmental audit is a critical examination of environmental protection activities at an industrial facility. This examination encompasses management systems, record keeping, operating procedures, previous history, community relations, and relations with all appropriate regulatory authorities. In 1986, the Environmental Protection Agency issued a policy statement on the issue of environmental auditing. In this policy it was implied but not specifically stated that the Agency would provide a more reasonable . enforcement attitude toward industrial operations which had installed a vigorous system of environmental auditing. Although this in no way condones or encourages the breaking of any laws or regulations, the policy is merely establishing an attitude of cooperation rather than one of police activity. Source: Mr. Hall is a corporate environmental manager with EKT, Houston, Texas. Presented at the National Petroleum Refiners Association Annual Meeting, March 20-22, 1988 (Technical Paper AM-88-24). Title: Authors: Doc. Type: Abstract: Envi Audits Source: Lawrence B. Cahill, Editor Book (6th Edition, October 1989) Discusses the concept of environmental auditing; its evolution, and advantages and disadvantages; perspectives of EPA and state regulatory agencies, including EPA's Environmental Auditing Policy Statement and the Agency's guidance on including audit provisions in settlement agreements; legal issues such as confidentiality and liability; planning and implementing an environmental audit program and evaluating the results; and techniques and tools for training auditors. Includes a section on international audits, a survey of audit programs of 20 companies, sample questionnaires, and audit checklists. Government Institutes Inc., 966 Hungerford Drive, #24, Rockville, MD 20850 A-l ------- Title: Author: Doc. Type: Abstract: Source: J. Ladd Greeno, Gilbert S. HedstrcEti, and Maryanne DiBerto Book (2nd Edition, 1988) Addresses the emerging principles as veil as the techniques of environmental- auditing, and provides practical guides to .audit program design and implementation. Includes appendices with audit protocols and questionnaires for air and water pollution and solid and hazardous waste management. Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn Park, Cambridge, MA 02140. Title: Authors: Doc. Type: Abstract: All About Environ .lental Source: Ridgway M. Kail, Jr. and David R. Case Book (1987) Describes the role of environmental audits in preventing violations, in assisting management to comply with regulations, and in ensuring compliance during growth and expansion. Presents an overview of environmental laws and regulations and their applicability to onsite operations. Outlines the procedures for planning and conducting an environmental audit, and for analyzing and using the results. Appendices include a questionnaire and sample inspection checklists for determining caipliance with various environmental laws, such as RCRA, TSCA, Clean Air Act, and Clean Water Act. Federal Publications Inc., 1120 Twentieth St. N.W., D.C. 20036 Washington, Title : Author: Doc. Type: Abstract: Environmental Institute for Environmental Auditing Book (late 1989) Describes the environmental auditing process, purposes and benefits of auditing, and the role of audits in the overall environmental management program. History and background of environmental audting, components of a successful program, types and uses of environmental audits, legal issues, and corporate program descriptions. Source: Springer-Verlag Publishers, 175 Fifth Avenue, New York, NY 10010 A-2 ------- Title: Author: Doc. Type: Abstract: Environmer Handbook Source: Lee Harrison, Editor Book (1984) Details corporate environmental risks arising from major environmental laws and how environmental auditing can reduce those risks. Includes a section describing the undertaking of an audit. Disclosure and confidentiality issues concerning the information generated by an auditing program are discussed. Explores these areas from the perspectives of: industry executives, auditors, engineers, insurance brokers, and federal regulators. McGraw-Hill Book Conpany, 64 Wboster Street, 2W, New York, NY •10012. Title: Environment"3 i Auditor Author: Articles are contributed by various authors Doc. Type: Professional Journal Abstract: The journal is devoted to the applied practice of environmental auditing, and is multidisciplinary in approach. Its thesis is that through environmental auditing, businesses can anticipate and manage pollution control problems and related environmental concerns, rather than being forced to react to crises as they occur. A typical issue will examine legal, scientific, and economic problems and solutions, and raise environmental issues for further analysis. Source: Published by Springer International, Springer-Verlag New York, Inc., 175 Fifth Avenue, New York, New York 10010. More information may be obtained from Robert S. DeSanto, Editor-in-Qiief, Environmental Auditor. P.O. Box 3818, Hartford, CT 06103 Title: Working Papers Author: Articles are contributed by various authors Doc. Type: Professional Newsletter Abstract: Working Papers is published quarterly by the Institute of Environmental Auditing for its membership. Typical contents include book reviews, meeting announcements, current developments, and letters to the editor. Source: Published by Institute for Environmental Auditing, P.O. Box 23686, L1Enfant Plaza Station, Washington, DC 20026-3686 A-3 ------- Title: "Advantages and Disadvantages of Environmental Auditing (Gleaned From Auditing Enforcement Settlements)" Author: Jonathan Libber, EPA Legal Enforcement Policy Branch Doc. Type: Report Summary (1988) Abstract: Evaluates the effect of including environmental auditing provisions in enforcement settlement agreements. Based on study which examined twenty settlement cases requiring compliance and management audits and containing a variety of settlement provisions. Demonstrates the benefits to regulated entities, including imprc/ed environmental management systems and business benefits; and identifies benefits to EPA, including savings in inspection and enforcement resources, and facilitation of follow-up inspections. Source: Available from Office of Enforoemerr- Policy, U.S. EPA Office of Enforcement and Compliance Monitoring, 401 M Street S.W., Washington, D.C. 20460 Title: "Benefits to Industry of Environmental Auditing" Author: Arthur D. Little, Inc., Center for Environmental Assurance Doc. Type: Report (August 1983) Abstract: Identifies principal objectives of environmental auditing programs and analyzes expected benefits to firms adopting environmental auditing programs. Benefits are categorized in terms of two main effects: (1) increased management effectiveness, and (2) increased management comfort or security that the company is meeting its legal, corporate and ethical requirements. Identifies measures to evaluate those effects. Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from the National Technical Information Service, U.S. Dept. of Commerce, Springfield, VA 22161; NTIS No. PB85-240422-AS. A-4 ------- Title: "Safety in the Chemical laboratory" Author: Kenneth E. Fischer Doc. Type: Periodical article Abstract: Discusses the use of audits by many laboratories, including sane in colleges and universities, to ensure that their hazardous waste handling operations are in compliance with state and federal regulations. Covers areas cannon to both state and federal regulations, including: waste determination; facility requirements; use of the manifest; vendor, transporter and site selection requirements; and training, contingency planning, and documentation. References for checklists are provided. Source: Journal of QienuV*-*i Education. Sgptgfrfr'*gi' 1987, pp A207-A210 — Pitfalls and Benefits" Title: "Internal Environmental Review Pi Author: Thomas D. Kent Doc. Type: Journal article Abstract: Allied's associate general counsel argues that using the term "audit" to describe internal environmental reviews might increase the risk of sanctions for negligent interpretations. Describes the genesis of the "environmental surveillance" program at Allied. Points out possible pitfalls in such programs, which are outweighed by far by the benefits. States that an ounce of cost-effective prevention in addition to making one feel good, is far better than a pound of lawsuits, cleanup schedules, and headaches. Source: Journal of the Water Pollution Oontrol Federation. March 1985, Vol. 57, No. 3, pp. 191-195. Title: "What Makes a Good Auditor?" Author: Environmental Auditing Roundtable Doc. Type: Brochure (December 1988} Abstract: Describes the attributes required of an individual for assignment as a lead auditor. Developed through a consensus process by members of the Environmental Auditing Roundtable. Essential auditor attributes identified are: objectivity; leadership skills; diplomacy; communication skills; working knowledge of relevant regulations; auditing skills; project management skills; and independence. Source: Environmental Auditing Roundtable, PO Box 23798, L'Enfant Plaza Station, Washington, DC 20026-3798. A-5 ------- Title: "Increased Assurance: The Response of Senior Management to Recent Environmental, Health, and Safety Events" Author: Gilbert S. Hedstrom Doc. Type: Conference paper Abstract: Reviews external and internal factors resulting in the development of environmental auditing as an environmental management tool to assure compliance. These factors include increased regulatory enforcement, internal cost control, integration of environmental health and safety programs, and decentralization. Describes the characteristics of leading environmental, health, and safety audit programs. Explores likely directions for this emerging discipline. Source: The author is with Arthur D. Little, Inc., Acorn Park, Cambridge, MA 02140-2390. Presented at the Annual Meeting of the American Institute of Chemical Engineers, August 24-27, 1986, Boston, MA. Title: "Who Should Conduct the Environmental Audit?" Author: D. A. Samela Doc Type: Conference paper Abstract: Reviews definitions of environmental auditing and outlines the elements of an effective environmental auditing system. Contrasts the advantages and disadvantages of performing an in-house versus using outside contractors. Concludes that well-established, larger firms would benefit from in-house audits while smaller, inexperienced firms may require external assistance. For any firm, an outside audit is recommended when the firm's public image is at stake. Source: The author is with Stone and Webster Engineering Corporation, 250 W. 34th Street, l Penn Plaza, New York, NY, 10119. Presented at the Annual Meeting of the American Institute of Chemical Engineers, August 24-27, 1986, Boston, MA. A-6 ------- Title: "Using Environmental Auditing as an Affirmative Compliance Tool" Authors: Mary Elizabeth Ford and Richard M. Oogen Doc. Type: conference paper Abstract: Identifies and describes three major types of environmental audits (pre-purchase, one-time or "snapshot", and continuing). Provides constructive guidance regarding; (1) determining the need for 'an environmental auditing program; (2) establishing an environmental auditing program; (3) maintaining confidentiality of audit information; (4) staffing the audit; (5} the use-of checklist, and questionnaire; and (6) the audit follow-up. Concludes that a well- implemented auditing program can aid a company in effectively making a transition from a reactive to an affirmative environmental compliance program. Source: Published in the Proceedings of the Industrial Waste Symposium at the 57th Annual Conference of the Water Pollution Control Federation, September 30-October 1, 1984. The authors are with Nixon, Hargrave, Devans, and Doyle, P.O. Box 1051, Lincoln First Tower, Rochester, NY 14603. Title: Authors: Doc. Type: Abstract: Source: "Environmental Audit Program Development.11 Joshua D. Margolis, Dennis E. Strutz, and Richard S. Krouse Conference paper Presents overview and brief history of environmental auditing. Provides questions about a company's current environmental management program to use in determining the need for environmental auditing. Discusses the different types and scopes of an EA program, the advantages and disadvantages, and the.issues that can be addressed. Reviews procedures for staffing and organization. Mr. Margolis is with IW/AER*X Division, 1625 I Street, NW, Suite 719, Washington, DC 20006. Presented at HazMat 1985, Philadelphia, PA. A-7 ------- ital Auditing and Title: "A Contingency View of Corporate Enviroi Iitplications for Public Policy." Author: Martin A. Smith Doc. Type: University dissertation Abstract: Analyzes the factors influencing management decisions on environmental auditing. Conpares characteristics of firms with auditing programs to those without and investigates reasons to establish programs, including efforts to meet societal responsibilities, protect reputations, and cope with increased complexity. Concludes that the major factor affecting the decision to establish auditing programs is the complexity of corporate environmental organization and activity. Source: Submitted to the faculty of the Department of Environmental Sciences and Engineering, University of North Carolina, Chapel Hill, NC, 1985. Title: "The Environmental Audit; Friend or Foe?" Author: Charles R. Goerth Doc. Type: Periodical article Abstract: Presents the views of a number of experts in the field of environmental auditing, including lawyers and EPA personnel. Explains that although an audit is no guarantee that EPA will not cite 'the company for any violations uncovered, it will help the ccnpany in its dealings with EPA. Lists the seven conditions for effective auditing specified in EPA's "Environmental Auditing Policy Statement", including support from top management, objectivity, regularity, and clear reporting. Source: Converting Magazine, pp 66-74, January 1987 A-8 ------- Title: "Environmental Auditing: Practices in Canadian Industry" Author: J.W. Reed Doc. Type: Journal article Abstract: Discusses the use of environmental auditing by Canadian firms as part of their overall approach to environmental protection and compliance assurance. Describes the results of a survey of the Canadian industrial sector, including the fact that individual firms use auditing programs to meet diverse objectives, such as verifying compliance with environmental regulations, identifying environmental risks and hazards, and limiting corporate liability. Source: Pulp & Paper Canada. Vol. 88, No. 6, June 1987. Title: Conservation Exchange Author: National Wildlife Federation Doc. Type: Newsletter Abstract: Several articles in the newsletter's Fall 1987 issue addressed different aspects of environmental auditing. Among aspects discussed are: the institutionalization of environmental auditing within industries; formation of environmental auditing organizations; reasons for popularity; benefits; and the lack of national certification standards for environmental auditors. Recommends industry efforts to establish uniform educational and professional standards for the field. Speculates that federal legislation mandating environmental auditing for regulated entities is not likely in the near future. Discusses the efforts of a few states to use legislative leverage to encourage environmental auditing. Source: Conservation Exchange. Vol. 5, No. 1, Fall 1987. Published by the National Wildlife Federation, 1412 Sixteenth St. N.W., Washington, D.C. 20036 A-9 ------- Title: "Environmental toil ting; A Review of Current Practice" Author: John W. Reed Doc. Type: university thesis Abstract: Describes environmental auditing and its roles and objectives in industry, drawing comparisons between EA and financial auditing. Defines the characteristics of audits with particular emphasis on management structure within the company conducting audits. Benefits of audits are seen to be an increased awareness of environmental regulations which would culminate in . increased environmental protection. Disadvantages are seen primarily to be the newness of EA, and the misunderstanding of ideas.. Identifies disclosure and confidentiality as issues that may be a disincentive to auditing. Source: Submitted to York University, March 1984. Resource Center, Faculty of Environmental Studies, York University, 333 Lumbers Building, North York, Ontario M3J 1P3. Also available from Publications, Conservation and Protection, Environment Canada, Ottawa Ontario KLA OE7 (Pub. Ref. # IP-17). Mr. Reed is with Texaco, Canada Inc., 1210 Sheppard Ave. East, Willowdale, Ontario M2K 2S8. Title: "Principles For conducting Environmental, Health, And Safety Audits (Discussion Draft)11 Author: Arthur D. Little, Inc., Center for Environmental Assurance Doc. Type: Pamphlet (1988) Abstract: Elucidates the emerging principles of auditing with a belief that the objectives and expectations that are being established for environmental, health, and safety auditing will be better served through increased attention to the basic tenets of auditing. Source: Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn Park, Cambridge, Massachusetts 02140. A-10 ------- Title: "Environmental Auditing: What Is It?" Author: John Palmisano and Malcolm C. Weiss Doc. Type: Journal article Abstract: States that different professional groups, each vying for auditing accounts, impart to it different attributes promoting their own interests. Notes three nyths about auditing: (1) disclosure problems outweigh the benefits gained by auditing; (2) benefits derived from auditing are primarily psychological, not financial; and (3) small businesses cannot adopt auditing because costs'are prohibitively high. Source: Environmental Analyst; Vol.4, Ho.ll, November 1983,'pp. 13-17. Title: ''Compendium of Audit Standards" Author: Walter Willborn Doc. Type: Report (1983) Abstract: Summarizes existing audit standards and guidelines issued by: the Institute of Internal Auditors, the American Institute of CPAs, Canadian Standards Association, ANSI/ASME, Government of Canada, and the U.S. General Accounting Office. Emphasizes commonalities among these standards. Addresses general features of audit standards and major audit issues such as: auditor requirements, organization, audit planning and procedures, audit reports, audit conpletion, and quality assurance. Source: American Society for Quality Control, 230 W. Wells Street, Milwaukee, Wisconsin 53203. A-ll ------- Title: "Benefits of Environmental Auditing: Case Examples" Author: Arthur D. Little, Inc., Center for Environmental Assurance Doc. Type: Report (Deceiriber 1984) Abstract: Documents the benefits of environmental auditing as reported by- managers responsible for their organizations' environmental audit program. In some cases, the examples illustrate actual benefits derived form individual audits, while in other cases the benefits result from having conducted a number of audits over a period of time. Provides insights into how environmental auditors conduct their field work, what type of situations they are liXely to uncover, and how facility-level environmental management can iaprove as a result of an audit. Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from the National Technical Information Service, U. S. Dept. of Commerce, Springfield, VA 22161; NTIS No. PB85-239531-AS. A-12 ------- B. AUDIT Title: "Environmental Auditing Skills and Techniques Workbook" Author: Arthur D. Little, Inc., for the Edison Electric Institute Doc. Type: Manual (1987) Abstract: Provides the field auditor with the basic skills and techniques needed to conduct an effective audit. Topics include the use of audit protocols and working papers; the interview process and ways to increase its effectiveness; understanding and assessing internal controls of the organization; sampling techniques; and evaluating audit results and reporting the findings. The workbook includes a comprehensive glossary of auditing terns. Source: Edison Electric Institute, Environmental Auditing Task Force, 1111 Nineteenth St. N.W., Washington, O.C. 20036 Title: Environmental Audit Protocol for EPA Faciliti**" (Final Draft) Author: U.S. Environmental Protection Agency Doc. Type: Manual (November 1986) Abstract: Protocol intended to serve as a guide for auditors to plan and conduct environmental audits at EPA facilities. Consists of four major sections: (1) Pre-audit activities (e.g. notification review of background information, agency contacts); (2) Understanding management systems (e.g. review of audit plan); (3) Gathering audit evidence (on different environmental areas); (4) Evaluating evidence and reporting findings. Includes observation checklist for air and water pollution, spill prevention, and hazardous waste management. Includes complete questionnaire. Source: Environmental Compliance Program, Occupational Health and Safety Staff (PM-273), U.S. Environmental Protection Agency, 401 M Street SW, Washington, DC 20460. B-l ------- Title: Author: Doc. Type: Abstract: Source: The Environmer^ai Handbook Series Various authors Sold as a five-volume set (1989) Breaks down each component of the auditing process and examines it in a separate handbook: 1.) planning, staffing, and contracting for an environmental audit; 2.) conducting an environmental audit; 3.) reporting, record keeping, and disclosure requirements for an environmental audit; 4.) ervironrnental auditing quality management; and 5.) how to prepare for a government inspection of facilities. Executive Enterprises Publications Go., Inc., 22 West 21st Street, New York, New Ycrk 10010-6904. Title: Author: Doc. Type: Abstract: A Procedure for Evaluating Hazardous Waste Vendors TRC Environmental Consultants, Inc. for Edison Electric Institute, Environmental Auditing Task Force. Manual (1986) Manual for use by an electric utility company to understand the benefits and purposes of auditing hazardous waste contractors, particularly to reduce waste generator liability. Reviews use of audit questionnaires. that assess technical, financial, and management aspects of vendors to determine risk potential. Discusses alternative approaches to performing audits, and includes saitple facility site audit (35 pp), telephone audit (4 pp), and property transfer audit (30 pp). Source: Edison Electric Institute, 1111 19th Street NW, Washington DC 20036. B-2 ------- Title : Author: Doc. Type: Abstract: The Envi yo Source: , H**j!lth. and Safety Auditor's Handbook J. Ladd Greeno, Gilbert S. Hedstrom, and Maryanne DiBerto Book (1989) Focuses on the needs of practicing environmental, health, and safety auditors and provides specific, practical advice on how to conduct effective audits. Information is provided on: 1.) field skills and techniques; 2.) principles to aid in a more systematic review of facility activities; 3.) techniques to ensure consistency among audit teams and across audits; 4.) approaches for developing clear and concise audit reports; 5.) checklists for ensuring quality in 'the audit process; 6.) examples of how to keepXworking papers, conduct interviews, and word audit findings. Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn Park, Cambridge, MA 02140. Title: Environmental Compliance Assessment and Management Program fECAMP) : Author: Doc. Type: Abstract: Source: U.S. Air Force Manual (1986) A protocol manual for conducting internal audits to assess the environmental compliance status of Air Force installations. Summarizes Federal, state, and local regulations, lists key compliance requirements, and provides protocol checklist for the following compliance categories: air emissions; wastewater discharge; solid and hazardous waste management; pesticides/herbicides; PCB management; drinking water; POL management; and hazardous materials management. Major Roy Solomon, AF/LEEV, Boiling Air Force Base, Washington, DC, 20332-5000. Availability of this document may be limited. B-3 ------- Title: Author: Doc. Type: Abstract: Source: A Practical H. William Blakeslee aid Theodore M. Grabowski Book (1985) Provides step-by-step advice on auditing a plant's compliance for air, water, waste, oil spills, toxic substances and others. Provides information for the engineer responsible for compliance, especially at small and medium-sized manufacturing and chemical plants. Van Nostrand Rheinhold Company, Inc., 135 West 50th Street, New York, NY, 10020. Mr. Blakeslee is with CertsinTeed Corporation, 1400 Union Meeting Road, Blue Bell, PA 19422. Mr. Grabowski is with Sun Refining and Marketing Company. Title: Multi-Media Compliance Audit Procedures Author: US EPA, National Enforcement Investigations Center Doc. Type: Manual (March 1989) Abstract: Details the procedures used by EPA or state inspectors authorized to conduct multi-media compliance inspections of facilities. The approach is intended to more effectively schedule the rtime of investigatory personnel and support a rational system for analyzing the compliance status of particular sources. Discusses the roles and responsibilities of inspectors. Source: U.S. EPA, National Enforcement Investigations Center, Federal Center, Bldg. 53, Box 25227, Denver, Colorado 80225. EPA Report No. EPA-330/9-87-001-R B-4 ------- Titles Enviypim>tai^ Basic Prineinl< Author: Doc. Type: Abstract: Source: Compliance Auditing Thomas H. Truitt, et. al. Book (1983) Comprehensively addresses the managerial, legal and procedural elements necessary to produce a quality environmental audit. The audit is characterized as a way to measure a plant's compliance performance against regulatory standards. Includes a lengthy section on planning and conducting audits as well as evaluating the data generated. Addresses legal issues arising from potential disclosure of audit information under SEC and major federal environmental regulations. Executive Enterprises Publications Co., Inc., 33 West 60th Street, New York, NY, 10023. Mr. Truitt is with Wald, Harkrader & Ross, 1300 Nineteenth Street NW, Washington DC, 20036 Title: "Can You Trust Your Environmental Auditing Program? Organizational Issues in Establishing and Improving Environmental Auditing Programs" Author: Alfred A. Marcus and Mark V. Nadel Doc. Type: Report (November 1983) Abstract: Discusses organizational issues affecting environmental audits and whether .managers can have faith in the capability and integrity of their auditing programs. Suggests factors managers may take into account when establishing or upgrading audit programs. Because so many variables exist with in a firm regarding audit systems, managers should take a position allowing them to evaluate evolving programs and make corrections when appropriate. Source: Prepared for Regulatory Reform Staff, U.S. EPA. Available from National Technical Information Service, U.S. Dept. of Commerce, Springfield, VA 22161; NTIS No. PB 85-240166-AS. B-5 ------- Title: "Reporting Environmental Audit Findings" Author: Ralph L. Rhodes Doc. Type: Conference paper Abstract: Discusses factors to be considered in assuring effective communication of environmental auditing results, including: (1) fundamental principles of effective communication? (2) appropriate reporting and confidentiality of information, and (3) opportunity for additional communication. Source: The author is with Allied-Signal, Inc. PO Box 2332R, Morristown, NJ, 07960. Presented at the Annual Meeting of the American Institute of Chemical Engineers, August 24-27, 1986, Boston, MA. Title: The Environmental Survey Author: U.S. Department of Energy Doc. Type: Manual (August 1987, update forthcoming) Abstract: Provides guidance to the U.S. Department of Energy's Survey & Sampling and Analysis teams conducting a one-time environmental survey of major DOE operating facilities. [This survey differs from an environmental audit: an audit is generally characterized as a regulatory compliance check that may also involve a review or critique of management systems. In contrast. the Survey is a compilation or inventory of environmental problems for purposes of prioritization. ] The various sections of the manual deal with: procedures and protocols to be used by the Survey teams; criteria to evaluate existing environmental data; generic technical checklists; health and safety guidelines for the personnel conducting the Survey; required formats for the Survey reports; issues of problem identification and prioritization; and sampling and analysis techniques. Source: U.S. Department of Energy, Office of the Assistant Secretary Environment, Safety, & Health, Office of Environmental Audit, 1000 Independence Ave., S.W., Washington, D.C. 20585. B-6 ------- Title: "An Approach to ES- & H Assurance Programs for Institutions" Author: Andrew Ellingson and Charles Trauth, Jr., editors Doc. Type: Report (September 1982) Abstract: A collection and condensation of material contained in 17 separate Sandia National laboratories' publications concerning Environmental, Safety and Health (ES&H) programs. Provides a detailed description of the components of an ES&H program including assurance, staff review activities and appraisals, institutional emergency response programs and institutional accident investigations. Source: Prepared by Sandia National laboratories, Albuquerque, New Mexico 87185. Volume I: Institutional ES&H Staff Functions available from National Technical Information Service, U.S. Dept. of Commerce, Springfield, VA 22161; NTIS No. DE-83-004254. Title: "Increasing the Effectiveness of Dwironmental Auditing Programs" Author: J. Ladd Greeno Doc. Type: Conference paper Abstract: Examines the impact of various program design and implementation considerations on the effectiveness of an audit program. Audit objectives, approach and staffing are key determinants of the effectiveness of an environmental audit program. It is important that these three aspects of the design and implementation of an audit program be congruent and mutually supportive. Source: Mr. Greeno is with the Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn Park, Cambridge, MA 02140. Presented at the 78th Annual Meeting of the Air Pollution Control Association, June 18, 1985. B-7 ------- Title: "Managing Your Environmental Audit" Author: David L. Russell Doc. Type: Periodical article Abstract: Discusses problems frequently uncovered during an audit and tips for conducting an audit. Suggests what a facility manager should consider before, during, and after an audit of his operations is conducted and what to do if serious problems are uncovered. Source: Chemical Engineering. June 24, 1985, pp. 37-43. Title: "Technical Considerations in Conducting a Hazardous Waste Facility Audit" Author: Edward Capasso Doc, Type: Conference paper Abstract: Discusses technical aspects to be considered in conducting an audit at a company-owned hazardous waste storage facility. Elements of an ' effective audit include management and team support, team objectivity, audit boundaries, and review procedures and follow-ups. Also presents procedures within the audit that should be given special attention. Source: The author is with Troy Chemical Corporation, 1 Avenue L, Newark NJ, 07105. Presented at HAZPRO, April 1986, in Baltimore MD. B-8 ------- CONFIDENTIALITY. DISCTflSURE. and OTHER irn&T. TRCTTFC TiUe: Author: Doc. Type: Abstract: "Practical Guidance For Due Diligence Environmental Auditing" J. M. DeMeester Journal article Environmental auditing has become one of the most widely used techniques for detecting and preventing environmental problems before they get cut of hand. Increasingly, corporations with sophisticated environmental staffs are using the technique to ' evaluate not only the corporation's own pollution concerns but also those of corporations that are possible partners in a merger or acquisition. Environmental auditing is thus becoming part of the '•due diligence" practiced in evaluating major business transactions. In this article, the author describes the needs for environmental due diligence auditing and the contractual issues underlying it. He explains how corporations should plan and carry out environmental due diligence auditing, and then analyzes typical problems that arise and evaluates responses to them. Source: Environmental law Reporter. Vol 18, June 1988, pp. 10210-10215. Title: "Risk of "Smoking Gun" Papers is Outweighed by the Benefits" Author: Thomas D. Kent Doc. Type: Periodical article Abstract: Focuses on the environmental compliance programs at a particular company, Allied-Signal Inc. Describes the corporate-wide "Environmental Surveillance Program"/ which is the company's tern for an environmental audit program. Raises the issue of potential penalties and liabilities arising out of accidental release of reports prepared as part of the program; and suggests ways to minimize the risk of potential damage to the ocnpany. Concludes that the economic, safety, and health benefits of such a program outweigh the risk of being found in non-oonpliance with regulations. Source: Preventive :, Vol. 6, No. 3, pp 12-16, September 1987 C-l ------- Title: Author: Doc. Type: Abstract: "Legal Considerations in Environmental Audit Decisions" Shell J. Bleiweiss Periodical article Discusses the legal benefits of conducting environmental' audits including assuring corporate compliance at the plant level, reducing potential liability, and iirproving public relations. Audits can also be critical factors in negotiating the sale or acquisition of property or stock. Concludes that audits roust be carefully planned to maximize credibility while protecting confidential and potentially damaging information. Source: Chemical Engineering Process. January 1987, pp 15-19 Title: "Duties to Report or Disclosure Information on the Environmental Aspects of Business Activities" Author: Environmental Law Institute Doc. Type: Report (September 1985) Abstract: Delineates corporate obligations to record and report information on the environmental and health impacts of their activities and EPA obligations to disclose or protect such information. Examines: (l) selected statutes and regulations; (2) SEC requirements; (3) common law; (4) ethical obligations under professional codes of conduct, and (5) EPA's obligations to report compliance information to the public. Lays out the factual background for EPA examination of environmental audit policy options. Source: Prepared for the Regulatory Reform Staff, FM-223, EPA, 401 M St., SK, Washington, DC 20460. C-2 ------- Title: "Corporate Brvironmental Compliance Programs" Author: Bradley I. Raffle Doc. Type: Conference paper Abstract: Discusses legal issues presented by corporate environmental quality assurance (audit) programs. Concludes that the benefits associated with these programs outweigh any legal concerns. As environmental compliance costs and liabilities escalate, such programs should gain even broader acceptance. Development would be advantageous to the public and environmental enforcement agencies as well as to the ccsnpaju.es that implement the programs. - -»•* Source: Mr. Raffle is Supervising Counsel with Conoco, Inc., PO Box 2197, Houston, TX 77079. Presented at the 78th Annual Meeting of the Air Pollution Control Association, June 18, 1985. Title: "Environmental Audits: Addressing Root Causes" Author: Richard Mays Doc. Type: Periodical article Abstract: An EPA enforcement attorney presents his personal views on the value of negotiating environmental auditing provisions in certain out-of-court settlements. By doing so, EPA would go beyond addressing only the outward manifestations of the problem (the violation) and respond to what may be the root cause of noncompliance: lack of adequate environmental policies and procedures. Source: Chemical JWeek. May 29, 1985, pp. 3-4. C-3 ------- Title: "Can What You Knew Hurt You as Much as What You Don't Know?" Author: Phillip D. Reed Doc. Type: Journal article Abstract: Suggests that increases in industrial auditing programs indicate a maturity of pollution control laws. Asserts that although industry is accepting environmental compliance, there are concerns about legal consequences and confidentiality of audit reports. Reviews EPA policy governing access to audits and questions use of audits in administrative enforcement actions. Source: grviro-m*»ntal lay Reporter. Vol. 13, No. 10, October 1984, pp. 10303-8. Mr. Reed is with the Environmental law Institute, 1346 Connecticut Avenue NW, Washington, DC 20036. Title: "Issues jf Confidentiality and Disclosure In Environmental Auditing" Author: Malcolm C. Weiss Doc. Type: Paper (April 1984) Abstract: Presents and analyzes legal issues surrounding the confidentiality of environmental audit generated information. Addresses the confidentiality and disclosure issues by examining to what extent audit information, if disclosed, could adversely affect its producer; and legal principles and developing case law which may be useful in securing legitimate confidentiality of audit information. Source: Prepared by Mr. Weiss while a member of the Regulatory Reform Staff, U.S. EPA. Available from the National Technical Information Service, U.S. Dept. of Commerce, Springfield, VA 22161; NTIS No. PBS5-239259-AS. C-4 ------- Title: "Safeguarding Confidential Business Information1' Author: Donald J. Henz Doc. Type: Conference paper Abstract: Suggests that certain information generated from an environmental auditing program will have to made confidential. Identifies auditing data that nay be used against a company, including information on capacity, production rates, process flow, expected life of facilities, and expenditures. Discusses methods to enhance confidentiality of data in the context of two rules: (1) never volunteer information and (2) maintain a confidential mentality. Source: FEDCO Environmental, Inc. 11499 Chester Road, Cincinnati, OH 45246. Presented at the 76th Annual Meeting, Air Pollution Control • Association, June 1983, Atlanta, GA. Title: "Environmental Auditing and Inspections" Author: David A. Giannotti Doc. Type: Report chapters Abstract: Describes the elements of an environmental auditing program including: company description, policy and organization, categorization of facilities, internal procedures for reporting environmental matters, and issues with unascertainable aspects. Discusses the issue of disclosure, concentrating on attorney-client privilege and the work product doctrine. Asserts that communications between an attorney and a client may be kept confidential, depending on how "client" is defined. Source: Report prepared for inclusion in Organizing Corporate Compliance Efforts (American Bar Association, June 1983) and Environmental Qjiu-iliance in a Gn^iefincf Tjscfal Environment (Practicing Law Institute, New York; Sept. 1983.) Mr. Giannotti is with Occidental Petroleum Corporation, 10889 Wilshire Blvd., Los Angeles, CA 90024. C-5 ------- Title: "Case Studies in Environmental Audits: A Practical Focus for Plant Managers and Auditors" Author: Stuart J. Spiegel and Cheryl L. Cundall Doc. Type: Conference paper Abstract: Argues that the objective of environmental audits is to evaluate procedures and practices that could results in systematic contamination, rather then to detect the potential for severe, one-time catastrophic releases. Includes four case studies which demonstrate the variety of problems that can be identified through an audit. Source: The authors are with O'Brien and Gere Engineers, Inc., P.O. Box 4873, Syracuse, NY 13221. Presented at the Annual Meeting of the American Institute of Chemical Engineers, August 24-27, 1986, Boston, MA. Title: "Current Practices in Environmental Auditing" Author: Arthur D. Little, Inc., Center for Environmental Assurance Doc. Type: Report (February 1984) Abstract: Discusses environmental auditing to further the understanding of how various ccqpanies approach the subject. Describes five individual environmental audit programs based on in-depth interviews with the companies' audit program managers. The companies interviewed represent a diversity of audit .approaches and have made significant commitments to their auditing efforts. Includes program documentation, e.g. checklists, protocols, and. audit reports, to illustrate the nature and scope of each program. Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from the National Technical Information Service, U.S. Dept. of Commerce, Springfield, VA 22161. NITS No. PB-240125-AS. D-l ------- Title: "Environmental Auditing Case Studies" Author: Arthur D. Little, Inc., Center for Environmental Assurance, for the Edison Electric Institute Doc. Type: Report (1984) Abstract: Similar to "current Practices in Environmental Auditing", this publication focuses on environmental auditing systems in the electric utility industry. Descriptions of five electric utility companies' audit programs are presented in considerable detail. Source: Edison Electric Institute, Environmental Auditing Task Force, llll Nineteenth Street NW, Washington, DC 20036. Title: "The Most Common Sins Discovered During Environmental Audits" Authors: David Brandwein and Gordon T. Brookman Doc. Type: Conference paper Abstract: Discusses the fourteen most common deficiencies discovered during audits conducted at more than 150 industrial operations in 30 states. Findings include inadequate waste containment, insufficient inspection of storage areas, lack of SPOC plan, and incomplete analysis of wastewaters. Concludes that many problems can be solved by better management practices and procedures rather than major capital improvements. Source: The authors are with Environmental Risk, Ltd., 120 Mountain Ave., Bloomfield, CT, 06002. Presented at the Annual Meeting of the American Institute of Chemical Engineers, August 24-27, 1986, .Boston, MA. D-2 ------- Title: "Another Approach to Environmental Auditing" Author: R. Victor Young Doc. Type: Conference paper Abstract: Traces the development of ARCO's environmental audit program and describes criteria for an effective audit, including management commitment; review scope, staffing, schedule, procedures, and reports; follow-up; and documentation. AROO's unique approach involves two levels of assurance: each division is given responsibility to conduct environmental audits, and there is an oversight corporate audit of the operating company's review programs. Source: The author is with the Atlantic Richfield Company, 515 South Flower Street, Los Angeles, CA, 90071. Prerented at the Annual Meeting of the American Institute of Chemical Engineers, Auqust 24-27, 1986, Boston, MA. Title: "Environmental Auditing: The Keystone to a Management Compliance, Control and Risk Assessment Program" Author: Robert W. Cutler Doc. Type: Journal article Abstract: Establishes a framework and analyzes characteristics of a viable environmental auditing program. Focuses on top management's commitment as the key to a successful system. Personnel training, preparation, field work and reporting are also considered basic aspects of a regulatory auditing program. Source: Environmental Analyst. April 1982, pp. 12-16. Mr. Cutler is Manager, Regulatory Audits, Olin Corporation, 120 Long Ridge Rd., Stamford, CT 06904. D-3 ------- Title: "Internal Environmental Audits - Assuring Compliance with the Regulations" Authors: Harold I. Goldsmith, Richard F. Picas, and John K. Williams Doc. Type: conference paper Abstract: Case history of Kraft's efforts to insure that individual locations comply with basic environmental regulations. Areas reviewed in each plant include: Wastewater discharges, spill prevention control and counter-measure plans, water supply, air emissions, other wastes and OSHA. Describes training and use of non-environmental professionals. Includes auditor's checklist. Source: The authors are with Kraft, Inc., Kraft Court, Glenview, IL 60025. Presented at the 58th Annual Conference of the.. Water Pollution "Control Federation, October 6-10, 1985, Kansas City', Missouri. Title: "Environmental Auditing - A Management Tool" Author: Patrick Atkins and Robert F. Kbhm Doc. Type: Conference paper Abstract: Discusses environmental auditing as implemented within the Aluminum Company of America (Alcoa) and focuses on auditing as a management tool. Covers the auditing program from conceptualization to current implementation. Concludes that auditing has proven to be an effective tool for improving environmental management even while on going changes. Source: The authors are with Aluminum Company of America, 1501 Alcoa Building, Pittsburgh, PA 15219. Presented at the annual meeting of the Environmental Division of the American Society of Civil Engineers, July 3, 1985. D-4 ------- Title: "General Motors Environmental Auditing Experience" Author: Joseph P. Barzotti and James R. Keller Doc. Type: Conference paper Abstract: Traces the development of and explains the auditing operation within General Motors Environmental Activities Staff. The audit program's focus is on prevention of problems. Its goal is to assure that all GM facilities achieve and maintain compliance with current and projected environmental laws, regulations and GM standards. Audit teams help share solutions to common problems among GM facilities. Self-identification of problems has enhanced the Corporation's reputation with government agencies at the local, state and federal levels. Source: The authors are with General Motors Corporation, General Motors Technical Center, Warren, MI 48090. Presented at the '.8th Annual Meeting of the Air Pollution Control Association, June 18, 1985. Title: "Environmental Auditing — TVA's Experience" Author: Edwin B. Robertson, Jr., and William M. Pearse Doc. Type: Conference Paper Abstract: TVA's auditing experience has been very satisfactory and auditing has become an important element of facility environmental management. Facilities and operations are audited against legislation, regulation, TVA policy, organization procedures, specific permits, NEFA documents and commitments to regulators. The program serves as a tool for regular intra-agency communication. Describes TVA's auditing process and one operating organization's reception to the program. Source: Mr. Robertson is Environmental Scientist, Envirx ital Quality Staff with the Tennessee Valley Authority, Muscle Shoals, AL 35660. Presented at the annual meeting of the Environmental Division of the American Society of civil Engineers, July 3, 1985. D-5 ------- Title: 'TMon Carbide Corporation's Health, Safety, and Bivironmental Protection Program" Author: Daniel C. Scheid Doc. Type: Conference paper Abstract: Describes the objectives, organization, staffing, scope, and reporting aspects of the corporate internal audit program developed by Union Carbide with the' assistance of Arthur D. Little, Inc. Focuses on the compliance audits, vised to determine compliance status of operating locations with respect to governmental and internal requirements. Outlines the audit methodology, including understanding and assessing management systems; and gathering, ..evaluating, and reporting audit findings. Source: 'The author is with Union Carbide Corporation, Old Ridgebury Road, Danbury, CT 06817. Presented at the Annual Meeting of the American Institute of Chemical Engineers, August 24-27, 1986, Boston, MA. Title: Author: Doc. Type: Abstract: Source: "Self-Auditing Program Monitors Compliance" Robert Cutler Periodical article Robert Cutler of Olin Corporation discusses environmental auditing based on his experience as manager of the Regulatory Compliance Audit Department. He believes a successful audit program requires (a) good people, (b) analysis of the regulatory requirements applicable to a company's operations, and (c) that the auditing office be kept independent of the activities being audited. Hazardous Waste and Pollution Management ftilletin. Vol. 1, B303, February 10, 1983, pp 1-2. D-6 L ------- Title: "A Utility's Experience With An Environmental Quality Assessment Program" Author: Kichael F. Basta Doc. Type: Conference paper Abstract: Details the background, scope and design of the Pennsylvania Power and Light (PP&L) auditing program to achieve environmental conpliance at its facilities. Explains the auditor's role as providing management assistance to the line organization so they may carry out the company's policies. Examines how two key business documents supply guidance, the assessment process and follow-up response. PP&L advocates auditing as a way that industry can take a leadership role in helping to inprcve the environmental regulatory process. Source: Pennsylvania Power and Light Company, Two North Ninth Street, Allentown, Pennsylvania, 18101. Presented at the 76th Annual Meeting of the Air Pollution Control Association, June 1983, Atlanta, Georgia. Title: "Environmental Auditing Policy: An Exploratory Analysis from the Corporate Perspective" Author: Martin A.' Smith Doc. Type: University paper (May 1983) Abstract: Examines how corporations might respond toward environmental auditing as a tool to achieve management goals, both for corporate activities related to the environment and for the company as a whole. Establishes three general categories as policy alternatives: (1) traditional non-auditing controls; (2) informal auditing; and (3) formal auditing. These categories form the vertical component of a matrix employing "criteria for choice" as the horizontal component. Concludes that after costs and benefits are weighed, corporate policy should include formal auditing as a management tool. Source: Institute for Environmental Studies, University of North Carolina 311 Pittsboro Street 256H, Chapel Hill, North Carolina 27514. D-7 ------- Title: Author: Doc. Type: Abstract: Source: "The EPA Manual for Waste Minimization Opportunity Assessments" US EPA, Risk Reduction Research laboratory Report (April 1988) The premise of this manual is that it makes far more sense to avoid generating pollution than to develop extensive treatment. schemes to manage pollution after it is generated. The manual outlines a step- by-step process for conducting waste minimization (or more broadly, pollution prevention) assessments to identify opportunities for source reduction and recycling in an industrial facility. Available from Regulatory Innovations Staff (PM-223), Environmental Protection Agency, Washington, DC 20460. U. S. Title: "Pollution Prevention Benefits Manual" Author: ICF, inc. for US EPA, Regulatory Innovations Staff Doc. Type: Report (September 1989) Abstract: Companion piece to opportunity assessment manual (above). Once pollution prevention options are identified through the assessment, this manual provides techniques for calculating tangible and intangible costs and benefits projected for each option. Title: "Selected Current Practices In Property Transfer Environmental Assessment" Authors: Policy, Planning & Evaluation, Inc. and ENSR Corp. for US EPA, Regulatory Innovations Staff Doc. Type: ^Report (March 1989) Abstract: "The primary objective of this report is to present information on how institutions and individuals involved in property transfers minimize their liability under SARA. This information will enhance the EPA's decision-making process, and will enable the Agency to assist and guide the regulated public. Source: Prepared for and available from Regulatory Innovations Staff (PM- 223), U.S. Environmental Protection Agency, Washington, DC 20460. E-l ------- Title: "Real Estate Transaction Envircranental Considerations" Author: J. Newton Abstract: After acquiring a new facility you discover that the previous owner had neglected the environment. There is substantial groundwater contamination; to clean it up will take more money than the facility cost. How could you have protected yourself? Doc. Type: Journal article Source: Pollution Engineering, Vol 20, No. 3, 1988, pp. 100-104. Title: "Environmental Audits in Connection with Property Purchases and Sales" Authors: Richard M. Cogen and Mary Elizabeth Ford Doc. Type: Conference paper Abstract: Discusses use of pre-purchase environmental audits to help companies make informed decisions about environmental risks posed by planned acquisitions or divestitures. Suggests that audits can save companies money by providing information relevant to decisions beyond the basic decision to buy or sell. Concludes that pre-purchase audits are a beneficial resource that all companies should consider when purchasing or selling property. Source: The authors are with Nixon, Hargrave, Devans, and Doyle, PO Box 1051, Lincoln First Tower, Rochester, NY 14603. Presented at the 78th Annual Meeting of the Air Pollution Control Association, June 18, 1985. Title: "Environmental, Health, and Safety Concerns in Acquisition Review11 Author: Jonathan Plaut Doc. Type: Journal article Abstract: Identifies three major concerns requiring consideration in any acquisition activity: (1) substantial hidden defects or problems (e.g. buried hazardous waste or emerging employee health problems), (2) environmental, health, or safety problems requiring significant capital expenditure, (3) overlooked latent opportunities revealing significant additional financial advantages to the buyer. Briefly discusses how acquisition teams should include these considerations in the audit of company being acquired. Source: Toxic Substances Vol. 2, No. 3, winter 1980-81, pp. 243-250. E-2 ------- Title: "Evaluation of Environmental 'Accident Risk Assessments in New1 Jersey" Authors: John R. Renella, Harold Christ iff, and Ramesh Kalagnanam Doc. Type: Conference paper Abstract: Reviews the N.J. Department of Environmental Protection's shift in policy regarding accidental releases of air contaminants. Discusses the "Environmental Accident Risk Assessments" conducted by two major chemical companies at the request of the OEP. The EARAs included a chemical screening analysis, detailed environmental accident assessment, and a remedial action plan. Results indicated numerous -deficiencies at both facilities. ~ n* Source: New Jersey Department of Environmental Protection', 383 West State St., Trenton, NJ 08618. Presented at the Annual Meeting of the American Institute of Chemical Engineers, August 24-27, 1986, Boston, MA. Title: "Ways to Avoid Liability when Purchasing Property" Author: Lawrence B. Canill and Raymond W. Kane Doc. Type: Book chapter Abstract: Suggests that an environmental audit can be an effective mechanism to identify potential liabilities during property transactions. Describes key steps in conducting an environmental audit: review of Federal, state, and local regulatory requirements; review of records and documentation related to environmental issues, for information on compliance with regulations; interviews with key staff; onsite physical inspection; risk evaluation; and reporting the audit findings. Provides exairples for each step, such as types of .regulations and ordinances to review, and suggests specific areas, --procedures, and equipment to inspect for audits of -various types of ^facilities. Source: Ewironmental Audits (6th Edition, 1989), Lawrence B. Cahill (Ed.), Government Institutes Inc., 966 Hungerford Drive, #24, Rockville, MD 20850 E-3 ------- Title: "A Systems Approach to Contingency Planning for Incidents Involving Hazardous Waste Materials" Authors: Jacqueline Shields, Richard C. Allison, Gary D. Holtzclaw, and Kirk C. Harlow. Doc. Type: Conference paper Abstract: Develops the use of a systems approach to developing contingency plans for hazardous waste releases and events. Using environmental audits, companies can identify areas with the greatest potential for uncontrolled events and can prioritize contingency planning efforts. Source: Dr. Shields is with the Environmental Management Program, School of Business and Public Administration, University of Houston-Clear Lake, Box 317, 2700 Bay Area Blvd, Houston, TX 77058. Presented at HAZPRO, April 1986, Baltimore, MD. Title: "New Perspectives on Corporate Risk and Ways to Reduce It" Author: Michael M. Gibson and Paul D. Fahrenthold Doc. Type: Journal articles Abstract: Part I: Suggests that corporate environmental affairs will change from being reactive to anticipatory in the relationship between corporate production and environmental activities. One need for this anticipatory approach arises from "toxic .tort" cases where liabilities may exceed the net worth of the company. Part II: Discusses attorneys' role in private-sector environmental audits in the context of information gathering and confidentiality. Explores competing demands an attorney may be subject to as corporate counsel involved with auditing. Suggests how attorneys should conduct themselves relating to ethics, who their clients are, how to exercise independent judgment, how to protect confidences and secrets, and what may occur when criminal conduct is found. Source: The Environmental Forum, Vol.1, No. 11, March 1983, pp. 35-41; Vol. 1, No. 12, April 1983, pp. 37-44. E-4 ------- Title: "Environmental Impairment Liability Insurance and Risk Assessment" Author: Paul Milvy Doc. Type: Journal article Abstract: Briefly discusses the insurance industry's initial attempts to insure against pollution episodes and focuses on environmental impairment liability (EIL) insurance. ETT. covers costs arising from non-sudden events, a type of coverage which was not previously available. Notes two main risks to be evaluated by underwriters in offering an appropriate policy: (1) the risk to the environment and public health and (2) the legal risks associated with a pollution ... incident. . . Source:"" The Environmental Forum. Vol.1, No.6, October 1982, pp. 30-37. Title: "Environmental Risk Assessments and Environmental Audits" Author: Richard S. Golob, Executive Editor Doc. Type: Periodical article Abstract: Presents an overview of insurance requirements and policy options for firms mandated to carry insurance to meet RCRA regulations. Includes summaries of insurance policies covering non-sudden pollution and profiles of environmental auditing and risk assessment firms. Source: Hazardous Intelligence Report r August 20, 1982, pp. 1-8. E-5 ------- Title: Author: Doc. Type: Abstract: Source: "Enviroranental Auditing Policy Statement" U.S. Environmental Protection Agency Federal Register notice EPA's final policy statement on environmental auditing encourages the use of auditing by regulated entities. Specifically encourages development and implement? tion of auditing programs in industry, and of initiatives of local governments. Discusses when the Agency may request audit reports and explains how EPA's enforcement activities may respond to industrial auditing efforts. Federal Regis ber Vol. 25004-25010. 51, No. 131, Wednesday, July 9, 1986, pp. Title: "Environmental Auditing: Reaching the Bottom Line in Compliance" Authors: Allen J. Danzig, Michael J. Walker, and Courtney M. Price Doc. Type: Journal Article Abstract: Describes EPA's efforts to encourage environmental auditing by regulated entities. Discusses the evolution of government and corporate interest in environmental auditing and its benefits; EPA's efforts to promote environmental auditing through policy statements; and major settlement agreements under TSCA and RCRA that contain environmental auditing provisions. Concludes that audit programs save money for regulated entities in the long run, and create an atmosphere of improved cooperation with regulated entities, while complementing the latters1 compliance efforts. Source: National Environmental Enforcement Journal. Vol. 2, No. 1, January 1987, pp 3-14. Published by the National Association of Attorneys General, Suite 403, 444 North Capitol St., Washington, D.c. 20001 F-l ------- Title: "Environmental Auditing; A Tool to Help Industry Identify and Environmental Risks" Author: U.S. Environmental Protection Agency Doc. Type: Newsletter (August 1989) Abstract: This issue of EPA's Oooperative Environmental Management M»?sacre discusses the benefits and potential pitfalls of environmental auditing, provides information on materials which are available to assist auditors, presents case examples, explores elements of effective audit programs, and reviews EPA's auditing policy. Source: Available from Regulatory Innovations Staff (PM-223), Office of Policy, Planning, and Evaluation, U;S. EPA, Washington, DC 20460. Title: "A Review of Environmental Auditing Activities in Federal Agencies" Author: Engineering-Science and Policy Planning & Evaluation Inc., for U.S. Environmental Protection Agency Doc. Type: Report (February 1987} Abstract: Reviews the status of environmental auditing activities of Federal agencies, and reports on emerging trends. For each existing Federal environmental auditing program, information is presented on: program status (comprehensive, partial, under development}; the number of facilities audited; frequency with which the facilities are audited; whether or not a formal protocol for auditing is used during the audits; scope of the audits (which environmental regulations or impacts the audit covers); and the source of auditing personnel (internal agency staff, contractor staff, etc). Source: U.S. EPA, Office of Federal Activities, Office of External Affairs, 401 K St. s.w., Washington, D.c. 20460 F-2 ------- Title: "Government Perspectives" Author: Tapio L. Kuusinen Doc. Type: Book chapter Abstract: Describes EPA's rationale for promoting environmental auditing, benefits to industry, EPA auditing policy, elements of effective auditing programs, federal agency auditing activity, state interest in environmental auditing, and special topic audits. Source: Environmental Audits (6th Edition, 1989), Lawrence B. Cahill (Ed.), Government Institutes Inc., 966 Hungerford Drive, #24, Rockville, MD 20850 Title: Authors: Doc. Type: Abstract: "Environmental Auditing; Developing a 'Preventative Medicine1 Approach to Environmental Compliance' Courtney M. Price and Allen J. Danzig Journal article Reviews EPA effort to encourage use of environmental auditing and development of EPA auditing policy with enphasis on Agency access to audit results. Explores the evolution of corporate interest in environmental auditing and identifies benefits gained by firms instituting auditing programs, includes major settlement agreements containing environmental auditing provisions. Source: Lovola of Los Review. Vol. 19, No. 4, pp. 801-824, 1986. Title: An Introduction to Environmental. Author: Environmental Law Institute for Michigan Department of Natural Resources (DNR) Doc. Type: Booklet (1985) Abstract: Summarizes reasons for undertaking audits and DNR's interest in auditing. Discusses alternative audit approaches, key elements of effective programs, how audits can be performed, and relevant recordkeeping and disclosure issues. Source: Local Assistance Section, Community Assistance Division, Michigan Department of Natural Resources, Box 30028, Lansing, MI 48909. F-3 ------- Title: "Environmental Auditing" Author: Fred Stiehl Doc. Type: Conference paper Abstract: Reviews state and federal approaches to the concept of environmental auditing and principles governing EPA's use of auditing in enforcement programs. Addresses two main concerns expressed in public comments to EPA's programs; (l) EPA request for audit reports and (2) potential use of audits in enforcement actions. Discusses current issues EPA is evaluating that will affect use of environmental auditing in enforcement settlements. Source: The author is with the Office of Enforcement and Compliance Monitoring, IE-134S, EPA, Washington, DC, 20460. Presented at HAZPRO, April 1986, Baltimore, MD. Title: A Ifandfcook of Envii North ial Auditing Perspectives in Author: Martin A. Smith Doc. Type: Report (1985) Abstract: Provides a brief description and history of environmental auditing and presents perspectives toward auditing of industry, the environmental community, environmental lawyers and local governments in North Carolina. Outlines four organizations' auditing systems, lists reference materials, and discusses important considerations in undertaking an auditing program, especially its potential for pollution prevention and hazardous waste minimization. Source: North Carolina Department of Natural Resources and Community Development, Pollution Prevention Pays Program, P.O. Box 27687, Raleigh, N.C. 27611. F-4 ------- Title: "Opportunities for Promotion of Environmental Auditing State-Level Initiative: Observations and Recxzntnendations Drawn From Other States" Author: Richard N. Andrews and Martin A. Smith Doc. Type: University paper (1983) Abstract: Examines environmental auditing using information gained through reports, journal articles, an informal survey of all states, and conversations with state and industry representatives. suggests alternate methods for promoting environmental auditing at the state level through legislation, administrative actions, enforcement programs, technical support and numerous private-sector efforts. Identifies methods for promoting environmental auditing among state industries and public-sector entities, and discusses what steps will be taken to institutionalize the state's auditing initiative. Source: Institute for Environmental Studies, University of North Carolina, 311 Pittsboro Street 256H, Chapel Hill, North Carolina 27r.14. F-5 ------- 1 .• ------- |