A REVIEW OF
ENVIRONMENTAL AUDITING
ACTIVITIES
IN FEDERAL AGENCIES
SUBMITTED TO:
U. S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D. C.
FEBRUARY 1987
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FINAL REPORT
A REVIE.W OF ENVIRONMENTAL AUDITING
ACTIVITIES IN FEDERAL AGENCiES
Contract No. 68-01-7252
Work Assignment 9
(Subcontract EPA 08-3)
TASK A
Submitted to
. ?""
Office of Fede.ral Activities (A-1 04)
Office of External Affairs
and
Regulatory Reform Staff (PM-223)
Office of Policy, Planning, and Evaluation
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
February 1987
FA006.02/15B-N
Submitted by
Engineering-Science
Two Flint Hill
10521 Rosehaven Street
Fairfax, Virginia 22030
In cooperation with
pOliby, Planning and Evaluation, Inc.
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DISCLAIMER
TABLE OF CONTENTS
CHAPTER 1
ACKNOWLEDGEMENTS
CHAPTER 2
CHAPTER 3
INTRODUCTION
SUMMARY OF EXISTING ENVIRONMENTAL AUDITING PROGRAMS
INFORMATION ON FEDERAL AGENCIES' ENVIRONMENTAL
AUDITING ACTIVITIES
Department of Agriculture
- AgriculturaL Research S~rvice
- Farmers Home Administration
- Forest Service
Department of Commerce
Department of Defense
- Department of the Air Force
- Department of the Army
- Army Corps of Engineers
- Army Environmental Office
- Army Materiel Command
- Defense Logistics Agency
- Department of the Navy
Department of Energy
Environmental Protection Agency
General Services Administration
Department of Health and Human Services
- Food and Drug Administration
- Indian Health Service
- National Institute of Health
Department of Housing and Urban Development
Department of the Interior
- Fish and Wildlife Service
- Bureau of Indian Affairs
- Bureau of Land Management
- Minerals Management Service
- Bureau of Mines
- National Park Service
- B~reau of Reclamation
Department of Justice
National Aeronautics and Space Administration
ii
iv
v
1-1
2-1
3-1
3-3
3-4
3-5
3-6 -
3-7
3-8
3-9
3-10
3-11.
3-12
3-13
3-15
3-16
3-17
3-18
3-19
3-20
3-21
3-22
3-23
3-24
3-25
3-26
3-27
3-28
3-29
3-30
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CHAPTER 3
APPENDIX A
TABLE OF CONTENTS
(CONTINUED)
FEDERAL AGENCY PROGRAM DESCRIPTIONS (CONTINUED)
Postal Service
Smithsonian Institution
Tennessee Valley Authority
Department of Transportation
- Coast Guard
- Federal Aviation Administration
- Federal Highway Administration
Department of the Treasury
- Bureau of Engraving and Printing
- Bureau of the Mint
Veterans Administration
3-31
3-32
3-33
3-35
3-36
3-37
3-38
3-39
3-40
EPA ENVIRONMENTAL AUDITING POLICY STATEMENT
A-1
iii
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DISCLAIMER
This report was furnished to the U.S. Environmental Protection
Agency by Engineering-Science, 10521 Rosehaven Street, Fairfax, Virginia,
in fulfillment of Subcontract No. EPA 08-3, Contract No. 68-01-7252, Work
Assignment 9, in cooperation with policy, Planning, and Evaluation, Inc.
of Vienna, VA. The opinions, findings, and conclusions expressed are
those of the authors and not necessarily those of the U.S. Environmental
Protection Agency. Similarly, mention of company or product names should
not be considered as an endorsement either by the U.S. Environmental
Protection Agency or by Engineering-Science.
iv
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ACKNOWLEDGEMENTS
This review was performed under subcontract to Policy, planning,
and Evaluation, Inc. (PPE) of Vienna, Virginia. PPE was also respon-
sible for gathering information on a portion of the agencies included
in this review. support from u.s. Environmental Protection Agency
personnel was also instrumental in producing this review, particu-
larly Len Fleckenstein of the Regulatory Reform Staff, and Jim Edward
and Lee Herwig of the Office of Federal Activities. '
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CHAPTER 1
INTRODUCTION
Environmental auditing is defined as use of a systematic, documen-
ted, periodic, and objective review by regulated entities of facility
operations and practices related to meeting environmental requirements.
Audits can be designed to verify compliance with environmental regula-
tory requirements, evaluate the effectiveness of environmental management
systems already in place, and to assess risks from regulated or unregula-
ted materials and practices. In this way, environmental auditing can be
an effective tool in an overall environmental management program.
These concepts are reflected in EPA's environmental auditing policy
statement (51 FR 25004, July 9, 1986; see Appendix A of this report).
Environmental auditing over the last several years has increasingly been
used to aid federal environmental program management. Just as managers
of industrial facilities need to know the status of their operations with
respect to environmental compliance and to identify potential environmen-
tal problems, managers of federal facilities need to be able to monitor and
control the environmental impacts of their operations.
Many federal agencies and departments are very cognizant of environ-
mental auditing procedures and principles. To encourage the development
of such programs, EPA sponsored a conference for federal agencies on
environmental auditing in February 1984. Among the subjects discussed
were goals of environmental auditing, designing auditing programs, and
specific audit procedures. Since that time, a number of agencies have
started auditing programs, and other agencies have studied how auditing
could be initiated. The purpose of this report is to review the status
of current environmental auditing activities of Federal agencies, and to
report any trends that have begun to emerge.
Information was collected for this report in a number of different
ways. First, published documents such as the recent report by the U.S.
Government Accounting Office* were collected and reviewed for up-to-date
information on auditing activities. Second, files of U.S. Environmental
* "Hazardous Waste: Federal Civil Agencies Slow to Comply with Regula-
tory Requirements,~" U.S Government Accounting Office, GAOjRCED-86-76,
Washington, DC, May 1986.
1-1
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Protection Agency offices involved with federal auditing activities were
reviewed to assess the scope and type of agencies' auditing programs.
Finally, follow up phone calls to certain key agency contacts were made
to obtain information not otherwise available. The results of this in-
vestigation are presented in Chapters 2 and 3. .
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C~T~ 2
SUMMARY OF EXISTING ENVIRONMENTAL AUDITING PROGRAMS
This chapter presents in a tabular form a summary of federal agency
environmental auditing activities for agencies that either have or are
actively developing an environmental auditing program (Table 2.1). Agen-
cies that do not currently have environmental auditing programs were not
included in the table. However, information concerning each of the 36
agencies reviewed can be found in Chapter 3.
Key information about each existing environmental auditing program
is presented. In each case, the following information is presented:
1 .
2.
3.
4.
Program Status - Programs are categorized as follows:
o
Comprehensive program - A formal permanent auditing program has
been established within the agency, including at least an evalua-
tion of facility compliance with all applicable federal, state,
and local environmental regulations. A comprehensive program
will generally have many, if not all, of the program elements
identified in EPA's environmental auditing policy statement (see
Appendix A).
o
Partial program - A formal permanent auditing program has been
established within the agency, but the scope is focused on one or
more specific topical areas. Agencies with partial programs may.
or may not have specific auditing procedures or plans for deter-
minin9 which facilities to audit.
o
Program under development - Developing programs may be charac-
terized by one or more activities such as: hiring a contractor
to develop an auditing protocol; initiation of the first formal
comprehensive audit; audits conducted on a limited number of
topical areas with firm plans for expansion into other areas;
or a management commitment to start a program during FY 87.
Number of Facilities - The number of facilities currently audited as
part of the agency's formal program is indicated.
Frequency of Audit - How often the number of facilities are audited
or are planned to be audited is indicated.
~
written Environmental Audjting Procedures - This column indicates
whether a formal protocol for auditing is used during the audits.
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'rA\II.E 2.1
StlMMAHY Ot' FEDERAl. AGENCY ENVIRONMENTAL AUDITING AC'rIVl'rIES
'"
I
'"
Number of Established Current SourCe of
Dept/ prcxJram Facilities Frequency Written Program Auditing
_Aqen~_- Status in Program of Audits Procedures Scope S ta f f
1\<;H/ Planned at 20 DCl'cndent Water and Water, wastewater,
Furest Pa I' t i a I sites per 2-) on facility wAstewater, underground storage Age ne y
Service Regions/year type among others tanks, HCHA, CERCLA
lindeI' develop-
COM ment (started To be Yes (being Agency &
Nov. 1986) 5 (planned) determined developed) Comprehensive Contractor
[)OD/Dept.
of the Air Comprehensive No 'set Agency &
Force 40 frequency Yes Comprehensive Contractor
000/ AMC - annual AMC - planned AHC-
Dept. of Comprehensive AHC-40 Othe rs - 3 Others -under Contractor
,the Army Others-11 to 5 yrs. development Comprehensive Others-AEHA
DOD/
Defense Comprehensive 24 Every Yes Comprehensive AEHA
Logistics 3 yrs.
,Agency
DOD/Dept.
of the Partial No set number No set Yes RCRA Agency
Navy frequency
Comprehensive
DOE (Started April Every Agency
1986) 40 (planned) 2 yrs. Yes Comprehensive
Every
EPA Comprehensive 13-15 per year 3 yrs. Yes Comprehensive Contractor
KEY TO DEPARTMENTS AND AGENCY ABBREVIATIONS
KEY TO .SOURCE OF AUDITING STAFF.
AGR
AMC
COM
000
DOE
EPA
GSA
HilS
NASA
TVA
DUT
THE
-Agriculture
-Army Materiel Command
-Commerce
-Defense
-Energy
-Environmental protection Agency
-General Services Administration
-llealth and lIuman Services
-National Aeronautics dnd Space
-Tennessee Valley Authority
-Tr.a ns Ix:>r ta ti on
-Trcdslll-y
Agency
AEHA
-Internal Agency staff
-Auditing by the Army Environ-
mental Health Agency
-Contractor auditing
Contractor
Admi n is h'a t i on
CON'l'INUED ON
NEX'r PAGE
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TAB/.E 2.1--Continued
""
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w
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Numher uf Estahlished Current Source of
I'ru'lram FaciLities Frcl)uency written l'ro'Jram Auditinq
Agency Status in rro(Jram __of Audits Procedures Scol'e Staff
Pilrtial.; PCUs, incinerators,
GSA revised To be To be Yes asbestos, and Agency &
proyram under determined determined storage tanks Contractor
development
IIIIS/Food &
Druq Under 2 No set Yes (being Comprehensive Agency &
Admin. development frequency developed) (planned) Contractor
IIIIS/Nat. Comprehensive pro-
Institute Comprehensive .12 Every Yes gram, issue-by- Agency
of Hea 1 th 2 yrs. issue audits
To be
NASA Comprehensive 9 determined Yes Comprehensive Contractor
Major fad 1-
i ties every
'IVA Comprehensive 30 2 yearsl Yes Comprehensive Agency
(to da te ) Others every
3 years
DOT/Coast 50 audited
Guard Partial within last 3 No set No RCRA Compliance Agency &
years frequency Contractor
TRE/Bureau
of Engrav. Under To be To be To be Comprehensive Contractor
& Printing development determined determined determined (planned)
TRE/ Under
Bureau of development 4 Annual No Water and hazardous Agency
the Mint (started 1986) waste
KEY TO DEPARTMENT AND AGENCY ABBREVIATIONS
KEY TO .SOURCE OF AUDITING STAFF.
AGR
MC
COM
000
DOE
EPA
(;5A
11115
NASA
'rvA
!JOT
TilE
-Agriculture
-Army Materiel Command
-Commerce
-Defense
-Ener
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5.
Current Program Scope - This column indicates whether current audit-
ing activities are limited to certain environmental regulations or
impacts.
6.
Agency/Contractor Auditing - The source of auditing personnel (such
as internal agency staff or a contractor's staff) is indicated.
A number of conclusions can be drawn from this information. Of the
36 agencies (or organizational units) reviewed in this report, 22 agencies
do not currently have an environmental auditing program as described above
under "Program Status". As explained previously, this situation does not
indicate that those agencies are not involved in environmental management
activities such as inspections, recordkeeping, and good operation and
maintenance procedures. Many of those agencies do in fact have signifi-
cant commitment to such activities as collecting, reviewing, and acting
on environmental information from their facilities (see Chapter 3).
Five agencies currently are in the process of developing environmen-
tal auditing programs. Each of these agencies has either started visit-
ing facilities, or has made a management commitment to develop a program
during FY 87. Four agencies are actively implementing partial programs;
one of these is GSA, which is currently developing a more comprehensive
program. Eight agencies presently have established formal comprehensive
environmental auditing programs, generally containing most, if not all,
of the environmental auditing program elements recommended by EPA in its
July 1986 environmental auditing policy statement (Appendix A). For ex-
ample, seven of the eight agencies that are indicated as having estab-
lished programs have formal written auditing procedures; the Army Mate-
riel Command is developing such procedures. Five of the eight agencies
that have established programs use contractors to conduct audits (at
least partially). All of the agencies that conduct environmental audits
themselves are organized in a way to assure independent review, such as
including special "environmental auditing" sections or staff from depart-
ment headquarters. An environmental staff person from each facility many
times performs as part of the audit team, but the headquarters staff is
ultimately responsible to report audit recommendations.
Other trends appear to be evident from Table 2.1. While there is
no set frequency of auditing for an individual facility, every two to
three years seems to be typical. . Most current and developing programs
are focusing comprehensively on all relevant environmental regulations
and impacts. To the extent that some programs concentrate on certain
issues, hazardous waste and water quality appear to be receiving the
most emphasis. A detailed description of each federal agency included
in the report follows in Chapter 3.
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CHAPTER 3
INFORMATION ON FEDERAL AGENCIES' ENVIRONMENTAL
AUDITING ACTIVITIES
This chapter presents an agency-by-agency description of environ-
mental and aUditing-related activities. After each program description
(including a contact's name, address, and telephone number), are specific
details of individual programs. In each case, the following information
is presented:
1 .
Program Status: Categorizes programs in the same way as in Chapter 2;
"Program Status" therefore describes the current state of an agency's
environmental auditing activities. If "No program" is indicated,
then the agency has no specific environmental auditing program (as
described on p. 2-1) as a part of its overall environmental manage-
ment activities. Other environmental compliance activities may of
course be proceeding. If an agency currently has no program, audit-
ing program information as described below is indicated as not appli-
cable (NA).
2.
Program Scope: To the extent that an agency has an environmental
auditing program, indicates how comprehensive in terms of environ-
mental issues the audits are designed to be. For example, if audits
are only designed to review compliance with RCRA regulations, this
focus will be reflected under "Program Scope."
3.
Agency/Contractor Auditing: Indicates whether audits are primarily
conducted by agency personnel, contractors, or a combination of the
two.
4.
Responsible Office(s): Provides a perspective on how an auditing
program is organized, the responsible offices, and/or organizational
units are presented. Generally, if the facilities or environmental
office of an agency's headquarters is responsible for an auditing
program (even if a contractor does the audits), then "Headquarters"
is indicated.
5.
Auditing Purpose: Lists three distinct purposes for on-going programs.
"Compliance Analysis" is focused on whether or not specific compliance
with environmental regulations is assessed (e.g., regulations estab-
lished under RCRA). "Management Review" is oriented towards ensur-
ing that effective management systems are in place and functioning.
"Liability Assessment" is oriented towards comprehensive evaluation
3-1
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of facilities' overall environmental impacts, regardless of whether
or not those impacts are specifically regulated.
6.
Audit Frequency: Indicates how often individual facilities are re-
quired to be audited.
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FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Agricultural Research Service/
Department of Agriculture
Contact/Title:
Ray Leaman, Director,
General Service Division
Address:
Room 329, Building 003
BARC West
Beltsville, MD 20705
Phone Number:
(301) 344-3522
Program Description: The Agricultural Research Service (ARS) presently
has no formal environmental auditing program. ARS has about 140 facility
locations with facilities ranging from small (two-men) research labora-
tories to operations with hundreds of staff utilizing several buildings.
The area offices (regional) cover a several-state area. The ARS performs
annual safety and health inspections from their area offices. ARS has
sent its facilities a questionnaire concerning RCRA, CERCLA, TSCA, and
FIFRA compliance. ARS hopes that the questionnaire will help them evalu-
ate their overall compliance status and to assess their environmental
auditing needs.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis NA
Management Review NA
Liabili ty Assessment.. NA
Audit Frequency:
NA
*As described on p. 2-1.
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Farmers Home Administration/
Department of Agriculture
Contact/Title:
John Hansel, Program Support Staff
Address:
Room 6309
Washington, DC 20250
Phone Number:
(202) 382-9619
Program Description: FmHA has no environmental auditing program in place,
but they are interested in environmental auditing programs to determine
potential liability when ~HA guarantees a business loan or takes tempor-
ary possession of business or farm property. FmHA does an environmental
assessment for loan guarantees on new businesses or business expansions
(e.g. a boat building business wants a loan to expand its business) or
when selling a business or'farm property that is to be used for a purpose
other than originally intended. The FmHA assessments are primarily con-
cerned with buried hazardous wastes.
Program Status:
No program*
Program Scope: . NA
Agency/Contractor Auditing:
NA
Responsible office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Forest Service/Department of Agriculture
Contact/Title:
Bill Opfer, Environmental Health Engineering
Address:
14th St. and Independence Ave., S.W.
Washington, DC 20250
Phone Number:
(202) 235-8019i (202) 447-4689 - Staff Office
Program Description: The Forest Service auditing program is under de-
velopment. The Forest Service has had a monitoring program in place for
about three years concerning environmental matters, covering over 6,000
ranger stations, campgrounds and picnic areas. Many of the facilities
have some form of water treatment (drinking water), waste treatment (sep-
tic tank or some waste process), and underground storage tanks. The
agency has policies and procedures for evaluating most of the environ-
mental areas, using primarily sanitary engineers in field visits. Head-
quarters office will typically monitor 20 sites in 2-3 regions each year;
regional offices monitor many additional sites each year. The cost of
visiting a site is several hundred dollars per site. When a facility is
visited, a written critique is sent to the facility. The Regions gener-
ally provide Headquarters with a corrective action report (although this
is not required).
The Forest Service believes that in the future they will have to emphasize
environmental programs related to RCRA and CERCLA. Some planning effort
has been recently started in these areas. Environmental Health Engineer-
ing at headquarters has responsibility for policy guidance, while regional
offices have technical compliance responsibilities.
Program Status:
Partial program established
Program Scope:
Will include water, wastewater, underground storage
tank requirements, RCRA and CERCLA
Agency/Contractor Auditing:
Agency
Responsible office(s):
Headquarters and Regional Offices
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
YES-partial
YES-partial
NO
Audit Frequency:
Varies by program and/or type of facility
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Department of Commerce
Contact/Title:
Ed Wilczynski, Acting Chief, Ecology and Conservation
Division
Address:
NOAA Ecology and Conservation Division (BF/ECD),
Room #6814, u.s. Department of Commerce, washington,
D.C. 20230
Phone Number:
(202) 377-5181
Program Description: The Department of Commerce is initiating an environ-
mental auditing program scheduled to begin in November 1986. Six sites
will be audited at first and then more will be audited if the audits un-
cover problems. The audits will examine five types of facilities: NOAA
fisheries laboratories, NBS underground storage tanks, NOAA vessel and
ship support facilities, the EDA Wisconsin Steel site, and the Patent and
Trademark Office microfiche processing facility. NOAA is responsible for
25 research vessels that are periodically maintained in ship support fa-
cilities, such as the one in Miami. The cost of total audit contract is
$35,000. Possible future sites include other Economic Development Admin-
istration (EDA) sites (businesses that were lent money, went bankrupt,
and were acquired by EDA), NOAA printing shops, and miscellaneous vehicle
fueling and maintenance operations. Audits will be conducted over a one
to three day period by the contractor and personnel from the agency
(either Ed wilczynski or David Cottingham). The written procedures are
being developed by the contractor. EPA has conducted formal training for
NOAA regional safety personnel in auditing procedures.
The Ecology and Conservation Division is now in the budget
likely to be transferred soon to the newly proposed Office
Scientist, NOAA. It will remain in the Office of the NOAA
separate from the five NOAA line offices.
office, but is
of the Chief
Administrator,
Program Status:
Program under development; was scheduled to begin
in November.1986
Program Scope:
Plan abbreviated audits of all media
Agency/Contractor Auditing:
Contractor plus one agency representa-
tive
Responsible office(s):
Headquarters
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
~S
Y~
NO
.
.-
..
Audit Frequency:
Not specified
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FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Department of the Air Force/Department of Defense
Contact/Title:
Capt. Gail Graben, Environmental Engineering
Project Office
Address:
Headquarters Air Force/LEEV
Bolling AFB, DC 20332
Phone Number:
(202) 767-4616
Program Description: The Air Force's environmental auditing program
began 2 years ago and thus far between 30 and 40 facilities have been
audited. The Air Force program consists of pilot programs run by
individual commands rather than a standard agency wide program. The
typical audit team consists of 3 or 4 people and they spend approximately
one week in the field per audit. The makeup of the team varies between
commands, but generally consists of either contractors or environmentally
trained Air Force personnel. A typical audit costs $25,000 - $30,000 if
performed by contractors and $12,000 - $15,000 if performed by Air Force
personnel. Air Force Headquarters has developed a written auditing
procedure and it is used as a guideline by the various commands. Following
an audit, the facility receives a written report of the audit findings.
The commands have the responsibility to see that audit recommendations
are implemented.
Program Status:
Comprehensive program established
Program Scope:
Comprehensive audits of all environmental media
Agency/Contractor Auditing:
Combination
Responsible office(s):
Each command
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
ns
NO
NO
Audit Frequency:
No set frequency
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FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Army Corps of Engineers,
Natural Resources Management Branch
Contact/Ti tle:
Mr. carl Brown, Chief
Address:
HQUSACE (DAE-CWO-R), 20 Massachusetts Ave., N.W.
Washington, DC 20314
Phone Number:
(202) 272-1789
Program Description: The civil works section of the Army Corps of Engi-
neers has management responsibilities for locks and dams on intercoastal
waterways in the u.s. The Corps generates and/or disposes of hazardous
materials in the form of oils, solvents, PCB'S, and contaminated dredged
material. Environmental compliance is handled by personnel at the dis-
trict level. Headquarters broadly reviews the management activities of
district personnel. The Corps currently does not have an environmental
auditing program.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Department of the Army, Army Environmental Office/
Department of Defense
Contact/Title:
Col. Thomas Magness, Chief
Address:
HQDA (DAEN-ZCE), Washington, DC
20310-2600
Phone Number:
(202) 694-1163
Program Description: The Department of the Army has a total of approxi-
mately 300 facilities. The audit program is established, but individual
commands have responsibility for their own facilities' program; commands
are therefore at different stages of development. In the past three
years, 11 audits have been conducted (exclusive of audits performed at
facilities of the Army Materiel Command -see program description on the
following page). Each audit has included air, water,. and hazardous waste
regulatory reviews. Personnel responsible for conducting the audits in-
clude personnel from the Army Environmental Hygiene Agency (AEHA), and
individual facility personnel (with environmental backgrounds). The team
usually consists of 8 to 10 people and each audit takes 3 to 5 days to
complete. AEHA is preparing written procedures so that audits can be
conducted by other personnel. A written report is prepared following
each audit, and each command is responsible for following up on audit
recommendations. Future plans include a comprehensive written audit
protocol.
Program Status:
Comprehensive program established
Program Scope:
Comprehensive audits of all media; also production
of guidance to commands concerning comprehensive
audit procedures
Agency/Contractor Auditing:
Each command and the Army Environ-
mental Hygiene Agency
Responsible office(s):
Each command
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
YES
YES
NO
Audit Frequency:
Every 3 to 5 years
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FEDERAL AGENCY AUDITING REVIEW
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AgencY/Department:
Department of the Army, Army Materiel Command
(AMC)/Department of Defense
Contact/Title:
Mr. Bill Hasselkus, Chief - Environmental Quality
Assurance
Address:
Headquarters, Army Materiel Command
5001 Eisenhower Avenue
Alexandria, VA 22333
Phone Number:
(703) 274-9016
Program Description: The AMC's environmental auditing program began one
year ago and thus far approximately 50 out of 65 AMC facilities have been
audited. The typical audit team consists of 3 or 4 people and they spend
approximately one week in the field per audit. The team is made up of
technical environmentally trained contractors. The typical audit costs
$15,000 to perform. AMC has planned formal written procedures for conducting
audits though these procedures have not yet been finalized. Following an
audit, the facility receives a written report of the audit findings. AMC
is responsible to see that audit recommendations are implemented. AMC
plans to switch to in-house auditing after all facilities have been
audited once by contractors.
Program Status:
Comprehensive program established
Program Scope:
Comprehensive audits of all environmental media
Agency/Contractor Auditing:
Contractor
Responsible office(s):
Headquarters
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
~s
YU
NO
Audit Frequency:
Annual
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FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Defense Logistics Agency/Department of Defense
Contact/Title:
Mr. Dennis Lillo, Environmental Protection Specialist
Address:
Environmental Protection Office
Cameron Station
Alexandria, VA 22304
Phone Number:
(703) 274-6967
Program Description: The DLA is a separate agency within DoD that runs
storage depots and supply centers. The DLA's environmental auditing
program began 2 years ago and thus far 24 out of its 25 facilities have
been audited. All media (i.e. air, water, hazardous waste) are included
in the audit. The typical audit team consists of 5 or 6 people and they
spend approximately 2 weeks in the field per audit. The team is made up
from the Army Environmental Hygiene Agency plus one representative from
headquarters. A typical audit costs $15,000 - $25,000 to perform. The
DLA has a formal written auditing procedure which they follow. The staff
is trained in auditing procedures. After a facility has been audited,
the facility receives a written report of the audit findings. The DLA
does follow up to ensure that audit recommendations are implemented.
Program Status:
Comprehensive program established
Program Scope:
Comprehensive audit of all environmental media
Agency/Cqntractor Auditing:
Army Environmental Hygiene Agency
and one representative from Head-
quarters
Responsible office(s):
Headquarters Environmental Protection Office
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
~S
YES
~S
Audit Frequency:
Each facility once every 3 years
3-11
-------
. I
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
u.s. Navy/Department of Defense
Contact/Title:
Carl Zillig
Address:
Office of the Chief of Naval Operations (OP 45),
Department of the Navy
Washington, DC 20350
Phone Number:
(202) 433-2069
Program Description: The Navy has conducted environmental inspections
for some time. The current auditing program, which is part of its over-
all environmental activities, is focused on RCRA. Six regional offices
of the Navy Energy and Environmental Support Command are responsible for
the audits, which include teams of one to three people who spend one to
four days at a facility. Audit teams use a guideline for their audits,
and reports are sent by the Energy and Environmental Support Command to
the facility and to responsible Command Admirals with a cover letter.
(Facilities which are audited may involve operations of more than one
command.) About 100 facilities a year have been audited in this way,
but auditing is only one of the environmental responsibilities of the
regional office staff and there is no established frequency for auditing
of any particular facility.
Program Status:
Partial program
Program Scope:
Predominantly RCRA facility audits
Agency/Contractor Auditing:
Agency
Responsible office(s):
6 regional engineering commands
Auditing Purpose:
Compliance Analysis YES
Management Review ~
Liability Assessment !£
Audit Frequency:
No set frequency
-
3-12
-------
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Department of Energy
Contact/Title:
John Barker, Director, Office of Environmental
Audit and Compliance
Address:
1000 Independence Avenue, S.W.
Washington, DC 20585
Phone Number:
(202) 252-5680
Program Description: The Department of Energy (DOE) is responsible for
the government's energy research and development programs, defense-related
activities, and other special energy programs such as the strategic petro-
leum reserves. To carry out these responsibilities, the Department owns,
and operates through contractual arrangements, many different facilities.
These facilities include plutonium and nuclear weapons producing plants,
metals processing plants, strategic oil reserves, electrical power trans-
mission facilities, and energy-related and environmental and bio-medical
research laboratories. To assess the environmental impacts of its opera-
tions, DOE has initiated an environmental survey which will ultimately
serve to establish priorities and develop long-range planning for cor-
recting environmental problems and reducing potential risks. In addition,
the Office of Environmental Audit and Compliance is to develop a program
of environmental audits which will be undertaken at the conclusion of the
survey in late 1988.
The survey includes on-site reviews of the physical environmental condi-
tions at individual facilities, interviews with key personnel, and sam-
pling and analysis of areas of potential environmental risk. The pro-
jected budget for the survey effort is $60 million. The survey is being
managed under the leadership of an Office Director with experience in
environmental auditing and compliance matters, and conducted by 5 teams
led and managed by DOE environmental professionals with experience in
environmental auditing and environmental regulatory compliance. The DOE
teams are supplemented with technical experts provided by a contractor.
Team members, including contractor support, are trained in-house in de-
tailed auditing procedures and environmental regulation. The survey is
then conducted through the use of a written manual which details proce-
dures and protocols to be followed. The on-site survey activities of
each site are documented by a written draft report. The draft report
is then revised to include the results of the sampling and analysis
performed at the particular site. Ultimately, a final report covering
all facilities will be written to document the entire survey, and will
include the prioritization of areas of environmental risk for corrective
action. The continuing program of environmental audits to be initiated
after the completion of the survey is currently being developed. DOE has
not yet decided whether the audits will begin only after the Survey is
completed, on the frequency of facility audits, or whether smaller facil-
ities will be included.
(continued on p. 3-14)
3-13
-------
Department of Energy (continued)
Program Status:
Comprehensive program established (survey phase)
Program Scope:
Comprehensive audits including all environmental
media
Agency/Contractor Auditing:
Combination
Responsible Office(s):
Headquarters" (Office of Environmental Audit
and Compliance) .
AUditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
YES
-
YES
YES
Audit Frequency:
To be determined
3-14
-------
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
u.s. Environmental Protection Agency
Contact/Title:
Karen Reed, Manager, Environmental Compliance
Program
Address:
401 M street S.W.
Washington, DC 20460
Phone Number:
(202) 382-3646
Program Description: EPA initiated an environmental auditing program in
early 1986. The present emphasis of the program is the multi-media envi-
ronmental auditing of EPA facilities (particularly laboratories). EPA
had a protocol developed by a consultant for auditing its laboratory fa-
cilities. Consultant teams were hired to perform the audits with an EPA
representative accompanying the team on some audits. EPA expects to have
13 audits completed in fiscal year 1986 (FY 86), and all its laboratory
facilities audited by the end of FY88.
The audit team members have environmental, chemistry and occupational
health backgrounds. After an audit, a draft report is written and sub-
mitted to the EPA's Environmental Compliance Program Manager. The draft
report and recommendations for corrective actions are then sent to the
audited facility. This facility in turn reviews and comments on the
draft report sending the comments and an Action Plan to Headquarters.
A final report is developed which then goes to the audited facility.
The final report and the Action Plan are distributed to EPA Regional
Offices and to the appropriate state. The environmental audits require
2-4 auditors at a facility for 2 to 3 days and the cost per audit (in-
cluding travel) is between $8,000 and $10,000. AUditing at EPA is the.
responsibility of the Headquarters Occupational Health and Safety Staff.
Program Status:
Comprehensive program established
Program Scope:
Comprehensive audits of all environmental media
Agency/Contractor Auditing:
Contractor with Headquarters support
Responsible Office(s):
Headquarters
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
ES
YES
YES
Audit Frequency:
Planned for once each 3 years
3-15
-------
.1
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
General Services Administration
Contact/Title:
Jeff Bauer, Chief, Safety and Environmental
Management Branch, Public Building Service
Address:
Room 4312, 18th and F Sts., N.W.
Washington, DC 20405
Phone Number:
(202) 566-1464
Program Description: GSA owns and operates buildings and has a total of
7,000 buildings they are contractually involved with. GSA has had a very
limited form of environmental auditing in the regions for about 5 years,
but mainly in the areas of asbestos and PCBs. For the last year, GSA
has made an effort to establish a centralized and broader (multi-media)
environmental auditing program using a contractor. GSA owns and operates
buildings and has a total of 7,000 buildings they are contractually in-
volved with.
The regional audits consist of two to three auditors visiting a building
site for a half-day or a depot for three days, and utilizing a RCRA/CERCLA
protocol developed by a contractor. The auditors' backgrounds usually
include fire protection, industrial health and environmental engineering.
GSA Regions have had some survey forms for inspecting incinerators, oil
tanks, PCBs, and asbestos. (The staff attends some seminars and short
courses on such subjects as hazardous waste site assessments.) When a
Regional Office visits a field facility, a report is written and sent
to the field facility. The Regional Office follows up on the report to
ensure field office corrections. The audit program is now being centra-
lized to achieve consistency across Regions and to make the audits more
comprehensive.
Program Status:
Program under development; partial program
established
Program Scope:
Audit mainly for PCBs, asbestos, incinerators, and
oil tanks
Agency jCon tractor Audi ting.:
Combination
Responsible Office(s):
Regional offices presently, but program
will be transferred to headquarters
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
YES
NO
NO
Audit Frequency~
To be determined
3-16
-------
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Food and Drug Administration/Department of Health
and Human Services
Con tact/Ti tie:
William H. Hoffman, Chief
Long Range Facilities Planning Staff
Address:
Food and Drug Administration
Rm 10-63 (HFA 205)
5600 Fishers Lane
Rockville, MD 20850
Phone Number:
(301) 443-4432
ProgramoDescription: A pilot environmental auditing program is currently
under development. The program will address multi-media pollution control
topics. The major focus of concern will be disposal of hazardous chemical
wastes from agency laboratories. Current plans are to have a contractor
develop a pilot auditing program for the FDA and initiate it in FY 1987.
Program Status:
Program under development
Program Scope:
Planned comprehensive audits for all media
Agency/Contractor Auditing:
Combination for pilot audits
Responsible Office(s):
He adq ua rte rs
,Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
YES (planned)
YES (planned)
NO
Audi t Frequency:
To be determined
3-17
-------
FEDERAL AGENCY AUDITING REVIEW
.1
~
1
'~
I
Agency/Department:
Indian Health Service
Division of Environmental Health/Department of
Health and Human Services
Contact/Title:
Bruce R. Chelikowsky
Chief, Environmental Management Branch
Address:
Parklawn Building
5600 Fishers Lane
Rockville, Me 20850
Phone Number:
(301) 443-1054
Program Description: The program of the Indian Health Service is oriented
towards a review of selected inspection reports focused on compliance. The
Service's inspections or surveys cover a broad range of facilities, rang-
ing from hospitals to restaurants, many of which are owned and operated by
other government agencies. Compliance with the requirements of federal
environmental statutes is one issue addressed in the Service's inspections.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-18
-------
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
National Institute of Health/Department of
Health and Human Services
Contact/Ti tIe:
Harvey Rogers, Chief, Environmental Protection Branch
Address:
Bldg. 13, Room 2E63
9000 Rockville Pike
Bethesda, MD 20892
Phone Number:
(301) 496-3537
Program Description: The National Institute of Health has a main campus
(300 acres with 40 buildings) in Bethesda, MD, and several smaller facil-
ities in other parts of the country. The National Institute of Health
has an active environmental auditing program and has been performing
audits for fifteen months. They have performed almost a dozen audits at
the main campus. Each audit is on a different issue, such as hazardous
waste, air pollution discharges, or infectious waste. The audit team
generally consists of three persons (an environmental auditing expert, a
scientist from a laboratory, and an administrative person), and requires
2-3 days of field work. The environmental staff receive short courses
and seminars on environmental regulations and the environmental experts
conduct a one-day training session before each audit. Written audit re-
ports are prepared and followed up with an action report. The auditing
function rests with the Environmental Protection Branch and other scien-
tists and administrative people are trained to execute the audits with
the environmental experts of the branch. Audit protocols have been.
written for two of the major field stations and a third one is presently
being developed. In the near future NIH will be promoting the implemen-
tation of environmental auditing at their field stations. .
Program Status:
Comprehensive program established
Program Scope:
Separate audits for each environmental medium
Agency/Contractor Auditing:
Agency
Responsible Office(s):
Headquarters, Environmental Protection
Branch
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
YES
YES
YES
Audit Frequency:
Once every 2 years
3-19
-------
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Department of Housing and Urban Development
Contact/Title:
Antionette Sebastian/Community Planner
Address:
Environmental Planning
Room 7152
451 7th Street, S.W.
Washington, DC, 20410
Division
Phone Number:
(202) 755-7225
Program Description: HUD has no formal auditng program in place at the
present time. HUD plans to develop a program in the future. CUrrently,
the department only manages single and multiple family housing in the
interim before foreclosure (90 days to 1-1/2 years). They are at most
small quantity generators of hazardous waste. The only environmental
problems identified to date include asbestos, lead (from pipes), and
disposal of cleaning and print shop materials.
Program Status:
No program.
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-20
-------
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Department of the Interior (Departmental level)
Contact/Title:
Bruce Blanchard, Director, Office of Environmental
Project Review
Address:
Office of Environmental Project Review
18th and C Sts., N.W. (HS-4239)
Washington, DC 20240
Phone Number:
(202) 343-3891
Program Description: The Department of the Interior has no formal auditing
program at the departmental level. They have approximately 26,000 struc-
tures that are principally offices or residences containing two to four
people. RCRA and specifically small quantity generator regulations are
of primary interest. They are conducting an in-house review to determine
which facilities are in fact small quantity generators.
Program Status:
No program* at the departmental level
Program Scope:
NA
Agency/Contractor Auditing:
NA
Reponsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audi t Frequency:
NA
*As described on p. 2-1.
3-21
-------
/
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
U.s. Fish and Wildlife Service/ Department of
the Interior
Contact/Ti tle:
Larry Shanks, Chief, Division of Environmental
Contaminants
Address:
Fish and Wildlife Service
(DEC/HAM-40l)
Washington, DC 20240
Phone Number:
(202) 343-5452
Program Description: The Fish and Wildlife Service currently has no
environmental auditing program. The Fish and Wildlife Service is very
decentralized, so much of the responsibility for complying with environ-
mental regulations rests with each individual facility. Fish and wildlife
conducts surveys to determine potential CERCLA sites, for example, but
neither the Division of Environmental Contaminants nor the Resource
Contaminant Assessment Division have inspectors (at headquarters).
people obtain training such as an introduction to contaminant laws
safety at Leetown, VA, a contaminant chemistry course at Columbia,
and the hazardous materials handling at Edison, NJ.
Field
and
Missouri,
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
. Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-22
-------
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Bureau of Indian Affairs/Department of the Interior
Contact/Title:
George Farris, Chief - Environmental Affairs
Address:
Mail Code 4558
1951 Constitution Ave
Washington, DC 20240
Phone Number:
(202) 343-4541
Program Description: The Bureau of Indian Affairs manages lands designated
as Indian reservations. The audit program is in the developmental stage.
The bureau plans to hire a contractor to conduct the Bureau's first audits.
The contractor would be responsible for having written audit procedures
and producing an audit report. The Bureau has not decided who will be
responsible for audit follow up.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audi t Frequency:
NA
*As described on p. 2-1.
t
3-23
-------
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Bureau of Land Management/Department of Interior
Contact/Title:
David Williams, Chief, Division of Planning and
Environmental Coordination (760)
Address:
Bureau of Land Management (909 Premier Building)
Department of the Interior
Washington, D.C. 20240
Phone Number:
(202) 653-8824
Program Description: The Bureau of Land Management (BLM) manages approxi-
mately 300 million acres of federal lands. The Bureau issues permits to
operations that are located on federal land, such as oil and gas drilling,
facilities and pipelines; grazing; mining of minerals; timber operations;
recreation; and power plants and transmission lines. The majority of BLM
offices are managed by GSA. At the present time, BLM has no environmental
auditing program.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
)1
Audit Frequency:
NA
*As described on p. 2-1.
.
.0
"...
. . .
3-24
-------
FEDERAL AGENCY AUDITING REVIEW
f
AgencY/Department:
Minerals Management Service/Department
of Interior
Contact/Title:
John Gull, Chief, Environmental Assessment Division
Address:
Reston, VA
22091
Phone Number:
(703) 343-2097
Program Description: The Minerals Management Service has no buildings of
their own and has no laboratory facilities. Their prime environmental
area of interest is in regulating the oil drilling performed by corpora-
tions. They do not have an environmental auditing program.
Program Status:
No program*
Program Scope:
NA
\
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-25
-------
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Bureau of Mines, Division of Property
Department of the Interior
Contact/Title:
Paul W. Johnson
Address:
Mail Station 215
2401 E Street, N.W.
Washington, D.C. 21240
Phone Number:
(202) 634-4750
Program Description: The Bureau of Mines operates approximately fourteen
field research laboratories across the country. At this time, they do
not have an environmental auditing program in place.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-26
-------
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
National Park Service/Department of the Interior
Contact/Title:
Mr. Don ~erring, Chief, Maintenance Branch
Address:
P.O. Box 37127
washington, DC
20013
Phone Number:
(202) 343-7040
Program Description: The National Park Service does not currently have an
environmental auditing program. They perform inspections, but there are no
written procedures for the inspections. The Park Service plans to develop
a formal auditing program in the future.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-27
-------
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Bureau of Reclamation, Office of Environmental
Technical Services/Department of the Interior
Contact/Title:
Mr. George Wallen, Chief, Office of Environmental
Technical Services
Address:
Code D-150, P.O. Box 25007
Denver, CO 80225
Phone Number:
(303) 236-9336
Program Description: The Bureau of Reclamation is the construction arm
.of the Department of Interior. The Bureau of Reclamation runs an inspec-
tion program through its Denver office that is primarily concerned with
hazardous waste management. The Bureau does not presently have an envi-
ronmental auditing program.
The current inspection program began approximately 18 months ago.
There are 6 regional offices each of which has a number of facilities
under its control. The inspection team generally consists of three
people - one from the Denver office and two regional people. These
personnel have technical backgrounds and spend 2 days in the field per
inspection. The cost of an inspection is $800 - $1,000. There is no
written inspection procedure. Inspection findings are included in a
travel report and submitted to the facility. The regional' director is
responsible for following up on inspection recommendations. The in-
spectors do not receive training in conducting environmental audits.
Program Status:
No program*
, Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-28
-------
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Department of Justice
Contact/Title:
Annette Perry, Space Management Specialist
Address:
1425 K Street, N.W.
Suite 700
washington, DC 20530
Phone Number:
(202) 633-2180
f'
~
Program Description: The Department of Justice is made up of six b~reaus:
the Drug Enforcement Agency (DEA), the Federal Bureau of Investigation
(FBI), the U.s. Marshall Service, the Immigration and Naturalization Ser-
vice (INS), the Bureau of Prisons, and the Offices of Boards and Divisions.
The DEA and FBI have laboratories and would be concerned with RCRA require- .
ments. The Bureau of Prisons has waste treatment facilities, manufactur-
ing processes, hospital facilities, and steam generating facilities in
various locations in the United States. The Department or the Bureaus
have no environmental auditing program at the present time. Environmen-
tal concerns at present are the responsibility of each Bureau Safety
Office. The Department is interested in developing audit programs for
the DEA, FBI, and Bureau of Prisons in the future.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-29
-------
'FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
National Aeronautics and Space Administration
Contact/Title:
Ms. Joyce Jatko, Real Estate Management Branch
Address;
400 Maryland Ave., S.W.
Washington, DC 20546
,Phone Number:
(202) 453-1962
Program Description: NASA's environmental auditing program began 2
years ago and 21 NASA facilities have been audited. The audits cover all
applicable environmental ,regulations and the overall environmental manage-
ment of the facilities. The typical audit team consists of 3 or 4 people
and they spend between 3 and 5 days in the field per audit. The audit
team is made up of environmentally trained contractors. A typical audit
costs $30,000 - $50,000 to perform. The audit contractors have standard
written procedures for conducting the audits. Following an audit, the
facility receives a written report of the audit findings. Currently, no
follow-up action is taken to ensure that audit recommendations are imple-
mented. Audits may be contracted out by either headquarters or the facility
itself .
Program Status:
Comprehensive program established
Program Scope:
Comprehensive audit of all environmental media
Agency/Contractor Auditing:
Contractor
Responsible Office(s):
Headquarters
Auditing Purpose:
Compliance Analysis
Management Review
~iability Assessment
YES
YES
YES
Audi t Frequency:
No specified frequency
..
"
3-30
-------
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
U.S. Postal Service
Contact/Title:
Ed Wande1t, National Environmental Coordinator
Address:
475 L'Enfant Plaza West, S.W.
Washington, D.C. 20260
Phone Number:
(202) 268-3135
Program Description: The U.S. Postal Service has several environmental
programs and is interested in environmental auditing. The Postal Service
has over 7,000 large buildings (over 5,000 sq. ft.) in urban areas. They
have approximately 300 vehicle maintenance repair facilities, 10 bulk mail
centers (about 100,000 sq. ft. with a10t of automation), and 300 general
mail facilities. Many of these facilities use substances currently regu-
lated under TSCA and RCRA.
~
r
The Postal Service has an Environmental Task Force which is comprised of
members from several departments. The Postal Service has five regions
and each region has an environmental coordinator. The Postal Service has
annual occupational health and safety inspections and has performed
surveys of PCB transformers, asbestos, and underground storage tanks.
The Postal Service is most concerned about old industrial sites acquired
for the development of large post offices, because of the possibility
of buried hazardous wastes and resulting liability. As a result, the
services performs environmental assessments of sites for 30,000 sq. ft.
buildings or greater, checking the sites for hazardous waste. At this
time a formalized environmental auditing program is not planned.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-~.
3-31
-------
FEDERAL AGENCY AUDITING REVIEW
AgencY/Department:
Smithsonian Institution
Contact/Title:
Jolanda Janczewski, Acting Chief, Safety Division
Address:
955 L'Enfant Plaza
Suite 3300
Washington, DC 20560
Phone Number:
(202) 287-3611
Program Description: The Smithsonian does not currently conduct environ-
mental audits. The Smithsonian conducts annual occupational health and
safety inspections which they hope to broaden to include environmental
auditing. They have a staff of inspectors, a few of which have some
environmental background, who observe and note environmental problem
areas on their inspections. The Smithsonian has a number of research
facilities and many of the museums have some type of laboratory included
in their facility. They also have some electroplating and painting
operations. The Safety Division plans to incorporate an environmental
auditing program in their annual inspection program.
Program Sta tus:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described on p. 2-1.
3-32
-------
~
FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Tennessee Valley Authority
Contact/Title:
John Thurmond, Head, Environmental Compliance
Auditing
Address:
309 Walnut street, Room 227
Summer Place Building
Knoxville, TN 37902
Phone Number:
(615) 632-6601
Program Description: TVA began conducting environmental compliance audits
in 1980. A formal auditing program was established in 1984, with the
overall purpose of evaluating and verifying environmental compliance, and
providing information to TVA management. The facilities audited include:
12 coal-fired steam plants; four gas turbine installations; three nuclear
plants; 29 hydroelectric plants; one pumped storage facility; the National
Fertilizer Development Center; and a large number of minor facilities and
activities. Major facilities aFe audited at least once every two years
and most minor facilities once every three years. Audits vary in length
from one day to over a week depending upon the facility being audited.
Audits encompass all environmental media, utilizing formal audit proce-
dures. Formal written reports are prepared and submitted to management
of the audited facility, the General Manager of TVA, and the Board of
Directors. All findings are tracked on a computerized tracking system.
TVA's annual environmental auditing budget is about $270,000, including
audits of private firms under contract for hazardous waste disposal.
The audit program consists of four members, a program head and three lead
auditors. It is located in th~ Environmental Quality Staff which has
corporate wide environmental compliance responsibilities. Occassionally
persons with special expertise from other TVA organizations and the pri-.
vate sector are used to supplement audit teams. Lead auditors are exper-
ienced and trained in auditing standards and techniques, and the program
adheres to recognized standards of professional internal auditing as
established by the Institute of Internal Auditors and the Comptroller
General of the United States. Lead auditors maintain close contact with
environmental auditors from other agencies and private industry.
Program Status:
Comprehensive program established
Program Scope:
Comprehensive audit of all environmental media
Agency/Contractor Auditing:
Agency
Responsible Office(s):
\
Corporate Headquarters/Compliance and
Permitting Group
(continued on p. 3-34)
/
3-33
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Tennessee Valley Authority (continued)
Auditing Purpose:
Audit Frequency:
Compliance Analysis
Management Review
Liability Assessment
YES
YES
YES
Major facilities - every 2 years
Minor facilities- every 3 years
3-34
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Agency/Department:
Contact/Title:
Address:
Phone Number:
FEDERAL AGENCY AUDITING REVIEW
u.s. Coast Guard/Department of Transportion
William McGovern, Chief
Environmental Compliance Section
u.S. Coast Guard Headquarters (G-ECV-5B)
2100 Second Street, S.W.
Washington, DC 20593-0001
(202) 267-1944
Program Description: The Coast Guard operates numerous air stations and
search and rescue stations in addition to their vessel fleet. Their en-
vironmental emphasis over the last three years has been on RCRA compliance,
and their audits to date have been limited to RCRA issues. Facilities
have been audited each year since 1984 according to the resources avail-
able, and as of the end of 1986, 50 facilities have been audited. Audit
teams have consisted of at least one representative each from Headquar-
ters, a district Coast Guard office, and a contractor provided by the
Defense Logistics Agency. No formal protocols are utilized. Written
reports are submitted to Headquarters and to the management of the
audited facility. Audits to date have cost less than $5,000 each.
Program Status:
Program Scope:
Partial program established
RCRA compliance
Agency/Contractor Auditing:
NA
Responsible Office(s):
Auditing Purpose:
Audit Frequency:
Headquarters
Compliance Analysis
Management Review
Liability Assessment
YES
NO
NO
No set frequency
3-35
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Federal Aviation Administration/Department
of Transportation
Contact/Title:
Tony Fazio, Economist
Address:
FAA-AEE110
800 Independence Avenue
Washington, DC 20591
Phone Number:
(202) 267-3564
Program Description: The FAA owns and maintains thousands of radar towers
and communication link systems throughout the United States. The FAA does
not have an environmental auditing program and tentatively has no plans
to implement one. A contractor conducted a survey of 40 sites this year
located in one of their nine regions, and found only 2 or 3 contained a
small amount of waste oil and stored cans of solvent. The solvent will
soon be replaced with aerosol spray cans (for cleaning contacts). They
do plan for the contractor to conduct a similar study for another region
to verify that environmental issues are of minimal concern. The FAA
thinks that an environmental auditing program will be 'unnecessary.
,
1
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described in p. 2-1.
3-36
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Federal Highway Administration/Department of
Transportation
Contact/Title:
Bernard Landry, Safety Engineer
Address:
HMS-4, 400 7th St., s.w.
washington, DC 20590
Phone Number:
(202) 366-0630
Program Description: FHWA has three material testing laboratories, a
research laboratory in McLean, Virginia, and several laboratory trailers
which they use on highway construction sites. While the FHWA presently
has no environmental auditing program, it does have a safety inspection
program that includes monitoring the handling and disposal of chemicals.
FHWA uses a large quantity of solvents for testing asphalt, and therefore
has some underground storage tanks and two hazardous waste storage tanks.
FHWA Headquarters inspects the laboratories at least every other year,
and is interested in tracking the chemicals at each facility from pur-
chase through disposal.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described in p. 2-1.
3-37
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Bureau of Engraving and Printing/Department of the
Treasury
Contact/Title:
Barbara Vaudreuil, Manager, Research and Development
Division
Address:
Bureau of Engraving and
14th and C Street, S.W.
Washington, DC 20228
Printing
Phone Number:
(202) 447-1361
Program Description: The Bureau manufactures plates, cylinders, and inks
which are used in-house to print paper currency, postage stamps and other
security documents. The main environmental concerns addressed by the
Bureau are VOC emissions, waste water discharges, and hazardous wastes
from the inks and solvents used in manufacturing securities and f~omlab-
oratory operations. At the present time, the Bureau has an active and
formal environmental compliance program. Under this program, the Bureau's
Environmental Subcommittee reviews equipment, materials and processes for
environmental compliance, obtains permits, performs monitoring and record-
keeping, and submits reports to federal and local environmental authori-
ties. The Bureau has committed to establish an internal environmental
auditing program during FY 87.
I
I
j
Program Status:
Program under development
Program Scope:
Comprehensive audit of all media (planned)
Agency/Contractor Auditing:
Contractor (planned)
Responsible Offices:
Office of the Assistant Director,
Research & Engineering
Purpose:
Compliance Analysis
Management Review
Liabilty Assessment
- YES (planned)
- ~ (planned)
- NO
Frequency:
Biannual
3-38
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Bureau of the Mint/Department of Treasury
Contact/Title:
Jerome Rellen, Chief, Assay Division
Address: .
Assay Division
633 3rd Street, N.W.
Washington, DC 20001
Phone Number:
(202) 376-0982
Program Description: The Bureau of the Mint started an auditing program
in 1986. They plan to audit each of their four coin processing plants
each year. The audits cover mainly water and hazardous waste concerns
at each facility, including laboratories. They have no written formal
auditing procedures at present, but plan to develop procedures for 'use
in the future. The audit team includes the Chief and two safety officers.
Written reports of each audit are prepared and corrective recommendations
are followed up.
Program Status:
Program under development
Program Scope:
Audits cover water and hazardous waste concerns
~
~
Agency/Contractor Auditing:
Agency
Responsible Office(s):
Headquarters (Assay Division)
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
~ (planned)
NO
NO
Audit Frequency:
Annual (planned)
r
3-39
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FEDERAL AGENCY AUDITING REVIEW
Agency/Department:
Veterans Administration
Contact/Title:
Jim Lefter, Associate Director
Engineering Service
Address:
Office of Facilities (088C)
Veterans Administration
810 Vermont Ave, N.W.
Washington, DC 20420
Phone Number:
(202) 233-3663
Program Description: The Veterans Administration (VA) has been conduct-
ing environmental and occupational health evaluations since 1976. Among
other activities, the VA has sent out questionnaires to its medical centers
concerning RCRA type waste, which it plans to follow up the questionnaire.
with some site visits. Much of the actual waste management responsibility
is decentralized (at each medical center). The VA is realigning some of
the environmental responsibilities at this level and it may be some time
before a clear definition of their future needs is possible. While the
VA currently has no environmental auditing program, it is planning to
assess its environmental auditing needs.
Program Status:
No program*
Program Scope:
NA
Agency/Contractor Auditing:
NA
Responsible Office(s):
NA
Auditing Purpose:
Compliance Analysis
Management Review
Liability Assessment
NA
NA
NA
Audit Frequency:
NA
*As described in p. 2-1.
\
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APPENDIX A
EPA ENVIRONMENTAL AUDITING POLICY STATEMENT
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Wednesday
July 9, 1986
Part IV
Environmental
Protection Agency
. Environmental Auditing Policy Statement;
Notice
\'
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"5004
"i.::~.;.:' .",
Federal Register I Vol. 51, No. 131 I Wednesday, July 9. 1986 I Notices
.,
NVIRONMENTAL PROTECTION
,GENCY
)PPE-FRL-3046-61
j
,
Environmental Auditing Policy
Statement
AGENCY: Environmental Protection
. Agency (EPA).
ACTION: Final policy statement.
SUMMARY: It is EPA policy to encourage
the use of environmental auditing by
regulated entities to help achieve and
maintain compliance with
environmental laws and regulations. as
well as to help identify and correct
unrp.gulated environmental hazards.
ErA first published this policy as
interim guidance on November 8.1985
(50 FR 465(4). Based on comments
received regarding the interim guidance,
the Agency is issuing today's final
policy statement with only minor
changes.
This Cinal policy statement
specifically:
. Encourases regulated entities to
develop, implement and upgrade
environmental audHing programs:
. Discusses when the Agenq mayor
may not request audit reports;
. Exp!ains how EPA's inspection and
enforcement activities may respond to
regulated entities' efforts to assure
compliance through auditing;
. Endorses environmental auditing at
federal facilities;
. Encourages state and local
environmental auditing initiatives; and
. Outlines elements of effective audit
programs.
Environmental audHing includes a
variety of compliance assessment
t~chniques which go beyond those
legalJy required and are used to identify
actual ar.d poter.tial environmental
problems. Effective environmental
auditing can lead to higher levels of
overall compliance and reduced risk to
human health and the environment. EPA
endorses the practice of er.vironmental
auditing and supports its accelerated
use by regulated entities to help meet
the goals of federal. state and local
environmental requirements, However.
the existence of an auditing program
does not create any defense to, or
otherwise limit. the responsibility of any
regu1ated entity to comply with
applicable regulatory requirements.
St& tes are encourased to adopt these
or simi!ar and equalJy effective policies
, in order to advance the use of
environmental auditing on a consistent.
r.ationwide basis.
DATES: This final policy statement is
effectivp. July 9. 1986. .
1
t
t
f
FOR FURTHER INFORMATION CONTACT:
Leonard Fleckenstein, Office of Policy.
Planning and Evaluation, (202) 382-
2726;
or
Cheryl Wasserman. Office of
Enforcement and Compliance
Monitoring. (202) 382-7550.
8UPPLEMENTARY INFORMATION:
ENVIRONMENTAL AUDmNG
POUCY STATDtfENT
L Preamble
On November 8. 1985 EPA published
an Environmental Auditing Policy
Statement. effecth'e as interim guidance.
and solicited written comments until.
January 7, 1986,
Thirteen commenters submitted
. written comments. Eight were frOm
private industry. Two commenters
represented industry trade associations.
One federal a~enC)'. one consulting firm
and one law firm also submitted
comments.
Twelve commenters addressed EPA
requests for audit reports. Three
comments per subject were received
regarding inspections. enforcement
response and elements of effective
environmental auditing. One commenter
addressed audit pro\;sions as remedies
in enforcement actions. one addressed
em'ironmental auditing at federal
facilities. and one addressed the
relationship of the policy statement to
state or local regulatory agencies.
Comments generally supported both the
concept of a policy statement and the
interim guidance. but raised specific
concerns with respect to particular
language and polic)' issues in sections of
the guidance.
General Comments
Three commenters found the interim
guidance to be constructive. balanced
and effective at encouraging more and
better environmental auditing.
Another commenter, while
considering the polky on the whole to
be constructi\'e. felt !hat new and
identifiable auditing "incentives" should
be offered by EPA. Based on earlier
comments received from industry, EPA
believes most companies would not
support or participate in an "incentives-
based" environmental auditing program
with EPA. Moreover. general promises
to forgo inspections or reduce
enforcement responses in exchange for
companies' adoption of em'ironmental
~ auditing programs-the "incentives"
most frequ'ently mentioned in this
context-ere fraught with legal and
policy obstacles,
Severa] commenters expressed
concern that states or localities might
use the interim guidance to require
auditing. The Agency disagrees that the
policy statement opens the way for
states and localities to require auditing.
No EPA policy can grant states or
-localities any more (or less) authority
than they already possess. EPA belie\'es
that the interim guidance effectively
encourages voluntary auditing. In fact.
Section U.B. of the policy states:
"because audit quality depends to a
large degree on genuine management
commitment to the program and its
objecti\'es. auditing should remain a
voluntary program."
Another commenter suggested that
EPA should not expect an audit to
identify all potential problem areas or
conclude that a problem identified in an
audit reflects normal operations and
procedures. EPA agrees that an audit
'report should clearly reflect these
realities and should be written to point
out the audit's li:nitations. However.
since EPA will not routinely request
audit reports.. the Agency does not
believe these concerns raise issues
which need to be addressed in the
policy statement.
A second concern expressed by the
same commenter was that EPA should
acknowledge that environmental audits
are onl)' part of a successful
environmental management program
and thus should not be expected to
cover every environmental issue or
solve a)) problems. EPA agrees and
accordingl)' has amended the statement
of purpose which appears at the end of
this preamble.
Yet another commenter thought EPA
should focus on em'ironmenta]
performance results (compliance or non-
compliance), not on the processes or
vehicles used to achieve those results. In
general. EPA agrees with this state:r.ent
and will continue to focus on .
environmental results. However. EPA
also believes that such results can be
improved through Ager.cy efforts to
identify and encourage effective
environmental management practices,
and will continue to encourage such
practices in non-regulatory ways.
A final general comment
recommended that EPA should sponso~
seminars for small businesses on bow to
start auditing programs. EPA agrees tha:
such seminars would be useful.
However. since audit seminars already
are available from several private sector
organizations. EPA does not belie~e it
should intervene in that market. WIth the
possible exception of seminars for
government agencies. especially federal
agencies. for which EPA has a broad
mandate under Executive Order 12088 to
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Federal Register I Vol. 51, No. 131 I Wednesday, July 9, 1986 I Notices
25005
provide tcchnical-assistunce for
environmental compliance.
Requests lor Reports
EPA received 12 comments regarding
Agency requests for environmental audit
reports. far more than on any other topic
in the policy statement One commenter
felt that EPA struck an appropriate
balance between respecting the need for
self-evaluation with some measure of
pri\"8cy. and allowing the Agency
enough fl£:xibility of inquiry to
accomplish future statutory missions.
However. most commenters expressed
concern that the interim guidance did
nol go far enough to Assuage corporate.
fears th3t EPA will use audit reports for
t:nvironmental compliance "witch
hunts." Several commenters suggested
additional specific assurances regarding
the circumstances under which EPA will
request such reports.
One commenter recommended that
EPA request audit reports only "when
the Agency can show the information it
needs to perform its statutory mission
cannot be obtained from the monitoring,
compliance or other data that is
otherwise reportable and/or accessible
to EPA. or where the Government deems
an audit report material to a criminal
investigation." EPA accepts this
recommendation in part. The Agency
believes it would not be in the best
interest of human health and the
environment to commit to making a
"showing" of a compelling information
need before ever requesting an audit
report. While EPA may normally be
willin~ to do so. the Agency cannot rule
out in advance all circumstances in
which such a showing may not be
possible. However. it would be helpful
to further darify that a request for an
audit report or a portion of a report
norrnnlly will be made when needed
inrlllT.l~tic.n is net available by
alternative means. Therefore. EPA has
revised Section IlI.A., paragraph two
and added the phrase: "and usually
made where the information needed
cannot be obtained from monitoring.
reporting or other data otherwise
available to the Agen~'."
Another commenter suggested that
(except in the case of criminal.
investigations) EPA should limit
requests for audit documents to specific
questions. By including the phrase "or
relevant portions of a report" in Section
1I1.A.. EPA meant to emphasize it would
not request an entire audit document
when only a relevant portion would
suffice. Likewise. EPA fully intends not
to request e\'en a portion of a report if
needed information or data can be
otherwise obtained. To further clarify
this point EPA has added the phrase.
"most likely fucused on particular
information needs rather tban the entire
report," to the second sentence of
paragraph two. Section IlI.A.
Incorporating the two comment8 above,
the first two sentences in paragraph two
of fin31 Section Ill.A. now read: "EPA's
authorit)' to request an audit report. or
rele\'ant portions thereof. will be
exercised on a ca8e-by-case basis wbere
the Agency determines it is needed to
accomplish a statutory mission or the
Government deems it to be material to a
criminal investigation. EPA expects such
requests to be limited, most likely
focused on particular information needs
rather then the entire report. and usually
made where the information needed
cannot be obtained from monitoring,
reporting or other data otherwise
available to the Agency."
Other commenters recommended that
EPA not request audit reports under any
circumstances, that requests be
"restricted to only those legally
required," that requests be limited to
criminal investigations. or that requests
be made only when EPA bas reason to
believe "that the audit programs or
reports are being used to conceal
evidence of environmental non-
compliance or otherwise being used in
bad faith." EPA appreciates concerns
underlying all of these comments and
has considered each carefully. However.
the Agency believes that these
recommendations do not strike the
appropriate balance between retaining
. the flexibility to accomplish EPA's
statutOT)' missions in future. unforeseen
circumstances, and acknowledging
regulated entities' need to self-evaluate
environmental performance with some
measure of privacy. Indeed, based on
prime informal comments. the small
number of formal comments received.
and the even smaller number of adverse
comments. EPA believes the IIlIal policy
statement should remain hugely
unchanged from the int~rim version.
Elements 01 Effective Enviror.rnentaJ
Auditing.
Three commenters expressed
concerns regarding the seven general
elements EPA outlined in the Appendix
to the interim guidance,
One commenter noted that were EPA
to further expand or more fully detail
such elements, programs not specifically
fulfilling each element would then be
judged inadequate. EPA agrees that
presenting highly specific and
prescriptive auditing elements could be
counter-productive by not taking into
account numerous factors which vary
extensively from one organization to
another, but which may still result in
effective auditing programs.
Accordingly, EPA does not plan to
expnnd or more fully detail these
'auditing elements.
Another commcnter asserted that
states and localities should be cautioned
DOt to consider EPA's auditing elements
as mandatory steps, The Agency is fully
aware of this concern and in the interim
guidance Doted its strong opinion that
"regulatory agencies should not attempt
.10 prescribe the precise form and
'.tructure of regulated entities'
environmental management or auditing
programs." While EPA cannot require
.tate or local regulators to adopt this or
similar policies, the Agency does
.trongly encourage them to do 80, both
in the interim and final policies.
A final commenter thought the
Appendix too specifically prescribed
what should and what should not be
included in an auditing program. Other
commenters, on the other hand. viewed
the elements described as VCT)' general
in nature. EPA agrees with these other
commenters. The elements are in no
way binding. Moreover. EPA believes
that most mature. effective
environmental auditing programs do
incorporate each of these general
elements in some form, and considers
them useful yardsticks for those
considering adopting or upgrading audit
programs. For these reasons EPA has
Dot revised the Appendix in today's
final policy statement.
Other Comments
Other significant comments addressed
EPA inspection priorities for. and
enforcement responses to, organizations
with environmental auditing programs.
One commenter, stressing that audit
programs are internal management
tools, took exception to the phrase in the
sp.cond paragraph of section 111.8.1. of
the interim guidance which states that
environmental audits can 'ccmplemel'!t'
regulatory oversight. By using the word
'complement' in this context. EPA does
not intend to imply that audit reports
must be obtained by the Agency in order
to supplement regulatory inspections.
'Complement' is used in a broad sense
of being in addition to inspections and
providing something (i.e.. self- .
assessment) which otherwise would be
'Iacking. To clarify this point EPA has
added the phrase "by providing self.
assessment to assure compliance" after
"environmental audits may complement
inspections" in this paragraph.
The lame commenter also expressed
concern that, as EPA lets inspection
priorities, 8 company having an audit
program could appear to be a 'poor
performer' due to complete and accurat.
reporting when measured against a
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Federal Register I Vol. 51. No. 131 I Wednesday. July 9. 1986 I Notices
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company which rr.ports son1ething less
than required by hlw. EPA agrees that it
is important to communicate this fact to
Agency and state personnel. and will do
so. However. the Agency does not
believe a ch~nge in the policy statement
is necessary.
A further comment suggested EPA
. should commit to take auditing.
programs into account when assessing
all enforcement actions. However. In
order to maintain enforcement flexibility
under varied circumstances. the Agency
cannot promise reduced enforcement
responses to violations at all audited
fucilities when other factors may be
overriding. Therefore the policy
statf!ment continues to state that EPA
nJi1V exercise its decretion to consider
auditing programs as evidence of honest
and genuine efforts to assure
compliance. which would then be taken
into account in fashioning enforcement
responses to violations.
A finHI commenter suggested the
phrase "expeditiously correct
environmental problems" not be used in
the enforcement context since it implied
EPA would use an entitv's record of
correcting nonregulated' matters when
evaluating regulatory violations. EPA
die! not intend for such an inference to
be made. EPA intended the term
"environmental problems" to refer to the
ur.derJying circumstances which
eventually lead up to the violations. To
clarify this point. EPA is revising the
first two sentences of the paragraph to
which this comment refers by changing
"environmental problems" to "violations
and underlying environmental .
problems" in the first sentence and to
"underlying environmental problems" in
the second sentence.
In a separate development EPA is
preparing an update of its January.1984
Federu/ Facilities Compliance Stroteg}'.
which is referenced in section Ill. C. of
the auditing policy. The Strategy should
be completed and available on request
from EPA's Office of Federal Activities
latp.r this \'car.
ErA thanks all commenters for
re~ponding to the November 8.1985
puhlication. Today's notice is being
issued to inform regulated entities and
the public of EPA's final policy toward
environmental auditing. This policy was
developed to help (a) encourage
regulHled entities to institutionalize
effective audit practices as one means of
improving compliance and sound
environmental managp.ment. and (b)
guide internal EPA actions directly
rclilted to reguillted entities'
environmental auditing programs.
ErA will evaluate implementation of
this final policy to ensure it meets the
above goals and continues to encourage
better environmental management.
while strengthening the Agency's own
efforts to monitor and enforce
compliance with environmental
requirements,
II. General EPA Policy on
Environmental Auditing
A. Introduction
Environmental auditing Is a
8~'stematic. documented. periodic and
objective review by regulated entities I
of facility operations and practices
related to meeting environmental
requirements. Audits can be designed to
accomplish any or all of the following:
verify compliance with environmental
requirements; evaluate the effectiveness
of em'ironmental management systems
alread.r in place; or assess risks from
regulated and unregulated materials and
practices. .
Auditing serves as a quality assurance
check to help improve the effectiveness
of basic environmental management by
verifying that management practices are
in place. functioning and adequate.
Environmental audits evaluate. and are
not a substitute for. direct compliance
activities such as obtaining permits.
installing controls. monitoring
compliance. reporting violations. and
keeping records. Environmental auditing
may verify but does not include
activities required by law. regulation or
permit (e.g.. continuous emissions
monitoring. composite correction plans
at wastewater treatment plants. etc.).
Audits do not in any way replace
regulatory agency inspections, Howe\'er.
em;ronmental audits can improve
compliance by complementing
conventional federal. state and local
oversight.
The appendix to this policy statement
outlines some basic elements of
environmental auditing (e.g.. auditor
independence and top management
support) for use by those considering
implementation pf effecti\'e auditing
programs to help achieve and maintain
compliance. Additional information on
environmental auditing practices can be
found in various published materials..
I "R~gulated entiti~." includ~ priv.t~ finna and
puLhc a8"nci~s with faciliti~. subi~cl to
er.,'ironm~nlal regulation. Public ag~ncie. can
include federal. 51ate or localagencie. 81 well 81
apecial.purpose organizations auch a. resion.1
.e",'age commissions.
~ I See. e.g.. "Cum!nt Practice. In Environmental
Auditinll." EPA Report No. EPA-~3-418.
F~bruary 1984: "Annolat~d Bibliography on
Environmental Audilil\ll," Fifth Edllion. September
1!1II5. both available from: Regulatol)' Reform Staff.
PM-ZZ3. EPA. 401 M Street S\\'. Wuhinston. DC
20460.
En\'ironmental auditing has developed
for sound business reasons. particularly
as a means of helping regulated entities
manage pollution control affirmatively
over time instead of reacting to crises.
Auditing can result in improved facility
environmental performance. help
communicate effective solutions to
common environmental problems. focus
facility managers' attention on current
and upcoming regulatory requirements.
and generate protocols and checklists
which help facilities better manage
themselves. Auditing also can result in
better-integrated management of
environmental hazards. since auditors
frequently identify environmental
liabilities which go beyond regulatory
compliance. Companies. public entities
and federal facilities have employ~d a
variety of environmental auditing
practices In recent years. Several
hundred major firms in diverse
industries now have environmental
auditing programs, although they often
are known by other names such as
assessment. surve~'. surveillance. review
or appraisal.
While auditing has demonstrated its
usefulness to those with audit programs.
many others still do not audit. .
Clarification of EPA's position regarding
auditing may help encourage regulated
entities to establish audit programs or
upgrade systems already in place.
B. EPA Encouroges the Use of
Em'jronmentaJ Auditing
EPA encourages regulated entities to
adopt sound environmental
management practices to improve
environmental performance. In .
particular. EPA encourages regulated
entities subject to environmental
regulations to institute environmental
auditing programs to help ensure the
adequacy of interna] systems to achieve,
maintain and monitor compliance.
Implementation of environmental
auditing programs can result in bett~r
identification. resolution and avoidance
of environmental problems. as well as
impro\'ements to management practices.
Audits can be conducted effectively by
independent internal or third party
auditors. Larger organizations generally
have greater resources to devote to an
internal audit team, while smaller
entities might be more likely to use
outside auditors. .
Regulated entities are responsible for
taking all necessary steps to ensure
compliance with environmental
requirements. whether or not they adopt
audit programs. Although environmental
laws do not require a regulated facility
to have an auditing program, ultimate
responsibility for the environmental
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Federal Register I Vol. 51, No. 131 I Wednesday, July 9, 1986 I Notices
2500
performance of the fllcility lies with top
management. which therefore has a
strong incentive to use reasonable
means. such as environmental auditing.
to secure reliable information of facility
compliance status.
EPA does not intend to dictate or
interfere with the environmental
management practices of private or
public.organizations. Nor does EPA
intend to mandate auditing (though in
certain instances EPA may seek to
include provisions for environmental
auditing as part of settlement
agreements. as noted below). Because
environmental auditing systems have
bee~ ~idely adopted on a voluntary
basIs In the past. and because audit
quality depends to a large degree upon
genuine management commitment to the
program and its objectives. auditing,
should remain a voluntary activity.
III. [PA Policy on Specific
Environmental Auditing Issues
A. Agency Requests for Audit Reports
EPA has broad statutory authority to
request relevant information on the
environmental compliance status of
regulated entities. However. EPA
believes routine Agency requests for
audit reports 3 could inhibit auditing in
the long run. decreasing both the
quantity and quality of audits
conducted, Therefore. as a matter of
poli.cy. EPA will not routinely request
envIronmental audit reports.
EPA's authority to request an audit
report. or relevant portions thereof. will '
be exercised or. a case-by-case basis
where the Agency determines it is
needed to accomplish a statutory
mission. or where the Government
deems it to be material to a criminal
investigation. EPA expects such
requests to be limited. most like!y
focused on particular informa tion needs
rather than the entire report. and usually
made where the information needed
cannot be obtained from monitoring.
repo.tmg or other da ta othe.wise
available to the Agency. Examples
would likely include situations where:
aud:ts are conducted under consent
decrees or other settlement agreements:
ij company has placed its management
practices at issue by raising them as a
defense: or state of mind or intent are a
relevant element of inquiry. such as
during a criminal investigation. This list
. An "en,'ironment.) audit report" i. a wrilten
repc"t \<;hl~h candidl)' and thorou~hly present.
findings from a revie\<;. conducted 81 part of IIn
environmental audit 81 described in aection 11..6... of
faciltl)' en\'ironmental performance and practice..
An 8ur111 report i. nol a suustilute for compliance
monJlortng report. or oth.r reports or record. which
m") be required by EPA or other regulatory .
"Ilt'-ncies. .
is illustrative rather than exhaustive.
since there doubtless will be other
situations. not subject 10 prediction. in
which audit reports rather than
information may be required.
EPA acknowledges regulated entities'
need to self.evaluate environmental
performance with some measure of
privacy and encourages such activity.
However. audit reports may not shield
monitoring. compliance. or other
information that would otherwise be
reportable and/or accessible to EPA,
even if there is no explicit 'requirement'
10 generate that data.. Thus, this policy
does not alter regulated entities' existing
or future obligations to monitor. record
or report information required under
environmental statutes. regl!lations or
permits. or to allow EPA access 10 that
information. Nor does this policy alter
EPA's authority to request and receive
any relevant information-including thai
contained in audit reports-under
various environmental statutes (e.g..
Clean Water Act section 308. Clean' Air
Act sections 114 and 208) or in other
administrative or judicial proceedings.
Regulated entities also should be
aware that certain audit findings may by
law have to be reported to government
agencies. However. in addition to any
such requirements. EPA encourages'
regulated entities to notify appropriate
State or Federal officials of findings
which suggest significant environmental'
or public health risks. even when not
specifically required to do so.
B. EPA Response 10 Environmental
Auditing
1. General Policy
EPA will not promise to forgo
inspections. reduce enforcement
responses, or offer other such incentives
in exchange for implementation of
environmental auditing or other sound
environmental management practices,
Indeed. a credible enforcement program
provides a strong incentive for regulated
entities to audit.
Regulittory agencies have an
obligation to assess source compliance
status independently and cannot
eliminate inspections for particular firms
or classes of finns. Although
environmental audits may complement
inspections by providing self-
assessment to assure compliance. they
are in no way a substitute for regulatory
oversight. Moreover, certain statutes
(e.g. RCRA) and Agency policies
. See. for exemple. "Dutie. to Report or Discloae
Information on the En,'ironmental Alpect. of
Businell Activitie.." En,'ironmental Law Inatitute
report 10 EPA. f,nal report. September 1985.
pstablish minimum facilitr ins. on
frequencies to which EPA will reo
However. EPA will continue to
address environmental problems on a
priority basis and will consequently
inspect facilities with poor
em'ironmental records and practices
more frequentl~'. Since effective
environmental auditing helps
management identify and promptl~'
correct actual or potential problems.
audited facilities' environmental
performance should improve. Thus.
while EPA in!lpections of self-audited
facilities will continue. to the exte:1t tha t
conlpliance performance is considered
in setting inspection priorities. facilities
with a good compliance history may be
subject to fewer inspections.
In fashioning enforcement responses
to violations. EPA policy is to take into
account. on a case.by-case basis. the
honest and genuine efforts of regulated,
entities to avoid and promptly correct
violations and underlying em'ironmento:,
problems. When regulated entities take
reasonable precautions to a\"oid
noncompliance. expeditiously correct
underlying environmental problems
discovered through audits or other
,means. and implement measures to
prevent their recurrence. EPA m~
exercise its discretion to consi ch'
actions as honest and genuine e s to' \
assure compliance. Such consideration
applies particularly when a regulated
entity promptly reports violations or
compliance data which otherwise were
not required to be recorded or reported
to EPA.
2. Audit Provisions as Remedies in
Enforcement Actions
EPA may propose environmental
auditing provisions in consent decrE'es
and in other settlement negotiations
where auditing could provide a remed'"
for identified problems and reduce the'
. likelihood of similar problems recurring
in the future.s En\"ironmen tal a udi ling
provisions are most Ijkely to be
proposed in settlement negotia tions
where: '.
. A pattern of violations can be
attributed. at least in part. to the
absence or poor functioning of an
environmental management system: or
. The type or nature of violations
indicates a likelihood that similar
noncompliance problems may exist or
occur elsewhere in the facility or at
other facilities operated by the regulatr:-c'
entity.
. EPA il developin~ ~uidan<.e for u~e b\' 8' '
ne~otialo" in structurin~ appropriate en~lro e~"
audit provi.ions for conaenl d.cree~ and olher
aellJement negoli..tions.
~
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25009
j
An effective environmental auditing
system will likely include the following
general elements: .
I. Explicit top management support for
em'ironmentaJ auditing and
commitment to foJJow-up on audit
findings. Management support may be
demonstrated by a written policy
articulating upper management support
for the auditing program. and for
compliance with all pertinent
requirements. including corporate
policies and permit requirements as wen
as federal. state and local statutes and
re~ulations.
Management support for the auditing
program also should be demonstrated
by an explicit written commitment to
follow-up on audit findings to correct
identified problems and prevent their
recurrence.
, II. An environmental auditing function
independent of audited actii'ities. The
status or organizational locus of
environmental auditors should be
sufficient to ensure objective and
unobstructed inquiry. observation and
testing, Auditor objectivity should not
be impaired by personal relationships.
financial or other conflicts of interest.
interference with free inquiry or
judgment. or fear of potential
retribution.
Ill. Adequate team staffing and
auditor training, Em'ironmental auditors
should possess or have ready access to
the knowledge. skills. and disciplines
,needed to accomplish audit objectives.
Each individual auditor should comply
with the company's professional
standards of conduct. Auditors. whether
full-time or part-time, should maintain'
their technical and analytical
competence through continuing
education and training,
IV, Explicit oudit program objectives.
scope. resources and frequency. At a
minimum. audit objectives should
include assessing compliance with
applicable environmental laws and
evaluating the adequacy of internal
compliance policies. procedures and
personnel training programs to ensure
continued compliance.
Audits should be based on a process
which provides auditors: all corporate
policies. permits. and federal. state. and,
local regulations pertinent to the facilit).;
and checklists or protocols addressing
specific features that should be
evaluated by auditors,
!
,
~
(
Explicit written audit procedures
generally should be used for planning
audits. establishing audit scope.
examining and evaluating audit findings.
communicating audit results. and
following-up.
V. A process which collects. anal}'zes.
interprets and documents infonnation
sufficient to achieve audit objectives.
Information should be collected before
and during an onsite visit regarding
environmental compliance(l). ,
environmental management
effectiveness(2). and other matters (3)
related to audit objectives and scope,
This information should be sufficient.
reliable. relevant and useful to provide a
sound basis for audit findings and
recommenda tions.
a. Sufficient information is factual.
adequate and con\-'incing so that a
prudent. informed person would be
likely to reach the same conclusions as
the auditor.
b. Reliable information is the best
attainable through use of appropriate
audit techniques.
c. Relevant information supports audit
'findings and recommendations and is
consistent with the objectives for the
audit.
d. Useful information helps the
organization meet its goals.
The audit process should include a
, periodic review of the reliability and
integrity of this information and the
means used to identify. measure.
classify and report it. Audit procedures.
including the testing and sampling
techniques employed. should be selected
in advance. to the extent practical. and
expanded or altered if circumstances
warrant. The process of collecting.
analyzing. interpreting. and
documenting information should provide
reasonable assurance that audit
objectivity is maintained and audit goals
are met.
VI. A process which includes specific
procedures to promptly prepare candid.
clear and appropriate written reports on
audit findings. corrective actions. and
schedules for implementation.
Procedures should be in place to ensure
that such information is communicated
to managers. including facility and
, corporate management. who can
evaluate the information and ensure
correction of identified problems.
Procedures also should be in place for
determining what internal findings are
reportable to state or federal agencies.
VII. A process which includes qualitp
assurance procedures to assure the
accuracy and thoroughness of
enn'ronmental audits. Quality assurance
may be accomplished through
supervision. independent internal
re\'iews. external reviews. or a
combination of these approaches.
Footnotes to Appendix
(11 A comprehensive assessment of
compliance with Cederal environmental
regulations requires an analysis oC facility
performance a(lainst numerous
en\'ironmental statutes and implementing
re(lulations. These statutes include:
Resource Consel"\'ation and Recover)' Act
Federal Water Pollution Control Act
Clean Air Act
Hazardous Materials Transportation Act
Toxic Substances Control Act
Comprehensive Environmental Response.
Compensation and Liability Act
SaCe Drinking Water Act
Federal Insecticide. Fungicide and
Rodenticide Act
Marine Protection, Research and Sanctuaries
Act
Uranium Mill Tailings Radiation Control Act
In addition. state and local (!cwernment are
'likel)' to have their own environmental laws,
Many states ha\'e been delegated authority te
administer federal programs, Many local
governments' building, fire, safety and heaJth
codes also ha\'e em'ironmental requirements
rele\'ant to an audit e\'aluation,
(2) An en\'ironmental audit could go well
beyond the t)'pe of compliance assessment
normally conducted during regulator)'
inspections. Cor example. by evaluating
policies and practices. regardless of whether
they are part of the environmental system or
the operating and maintenance procedures,
Specifically. audits can evaluate the extent to
which systems or procedures:
1. Develop organizational environmental
policies which: a. implement regulatory
requirements: b, provide management
guidance for environmental hazards nc!
specifically addressed in re(luJations:
2, Train and motivate facility personnel to
work in an environmentally-acceptable
manner and to understand and comply with
government regulations and the entity's
em'ironmental policy:
3, Communicate relevant environmental
. developments expeditiously to facility and
other personnel:
4, Communicate effectively with
government and the public regarding serious
environmental incidents:
5, Require third par,Ii'!s working for. with o~
on behalf of the orga:,i:..:~tion to follow its
environmental procE'u~~~s:
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Federal Register I Vol. 51. No, 131 I Wednesday. July 9. 1986 I Notices
. Thruugh this t;onsclIl dcr.ree approach
und other means. EPA may consider
how to enr.ollriige effective auditing by
publicly owned sewRge treatment works
(POn';,'s). POTWs often have
compliance problems related to
operlltion and maintenance procedures
which clln be addressed effectively
through the use of environmental
auditing. Under its National Municipal
PuJi<:~' EPA already is requiring many
POTWs 10 develop composite correction
plan!; to identify and correct compliance
probl;:ms.
C. Em'ir
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Federal Register I Vul. 51. No. 131 I Wednesday. July 9. 1986 I Notices
fl. MHI..,~ prond'!nl p~l"!Ionnelll\'ailable at
0111 tim"s to cHrry out envirunmental
("s~"'l:iHlly emt'I'Rcncy) procedures;
";. Im:urporulc environmental protection
inlu wr,tlcn opcrilting procedures:
8. Apply best manllgemen! prllctices and
ol'l'TiltillR prllcedul1'S. including "800d
tWIIsl'l.:ef'ping" tf'chniques:
9. In~ti:ule preventive and corrective
'mllintcnanr.e systems to minimize actual and
poll'nlial en\.irnnmenlill hllnn:
"I. Utiljze best 8\"aiJilhl~ proce&5 and
r.unlroltechnol(J!!ie~:
1,. USf' mo~t-effP.r.ti\"e sHmplini! and
ml.::j!,,~jl;,c te::hni4u£~. lest met nods.
rf'C"ordkeering syslcm~ or reportinp protnco!s
p"'...nnr! minimum legHI rt'quircmenls):
1:!. F.\.a!uHle cau~es behind any serious
f'n\.irun~I'ntal inticir>nts anci e~tablish
rr.It:t'dun:s 10 ..vuid returrence:
13. Ex?I'Ji! sO:Jrc(' reduction. recycle and
rf'U~I' j.:n:(:r!lial ,,-ncrever pructical: and
1~. Sd'slitulP maleriuls or processes 10
..!inw UM' of 11-." ll'a~l.holzardou~ sunslanc!'6
If..o;ih:~. .
(,;1 Auditul ~ cuu!d illso a~SFSS
rT'\'Jrllj~rr.P'Hii! rjsk~ i1nd uncertainti~s.
In~ nn.~ 8&-15~:!3 Fill'\! 7-8-Rt; 8.~5 dOl)
81~ItIG CODE IS6D-5O-foI
)
!
r
I
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