EPA's Environmental Audit Protocols: Tools for Compliance

Are the  Audit  Protocols
Available  Now?

Nine of the audit protocols have already been completed
and are available to the public:

Protocol for Conducting Environmental Compliance
Audits of Hazardous Waste Generators under the
Resource Conservation and Recovery Act (EPA
Document No., EPA-305-B-98-005)

Protocol for Conducting Environmental Compliance
Audits of Treatment Storage and Disposal Facilities
under the Resource Conservation and Recovery Act
(EPA Document No., EPA-305-B-98-006)

Protocol for Conducting Environmental Compliance
Audits under the Comprehensive Environmental
Response, Compensation, and Liability Act (EPA
Document No., EPA-305-B-98-009)

Protocol for Conducting Environmental Compliance
Audits under the Emergency Planning and
Community Right-to-Know Act (EPA Document No.,
EPA-305-B-98-007)

Protocol for Conducting Environmental Compliance
Audits of Facilities Regulated under Subtitle D of
RCRA (EPA Document No., EPA-300-B-00-001)

Protocol for Conducting Environmental Compliance
Audits of Used Oil and Universal Waste Generators
under the Resource Conservation and Recovery Act
(EPA Document No., EPA-300-B-00-002)

Protocol for Conducting Environmental Compliance
Audits of Storage Tanks under the Resource
Conservation and Recovery Act (EPA Document No.,
EPA-300-B-00-006)

Protocol for Conducting Environmental Compliance
Audits of Facilities with PCBs, Asbestos, and Lead-
based Paint Regulated under TSCA (EPA Document
No., EPA-300-B-00-004)
Protocol for Conducting Environmental
Compliance Audits of Public Water Systems
under the Safe Drinking Water Act
(EPA Document No., EPA-300-B-00-005)

EPA expects to issue four more audit protocols to the
public by December 2000. These include: Management of
Pesticides; Clean Air Act, Clean Water Act and TSCA.
How  do  I  get copies  of
the  protocols?

The audit protocols have become some of EPA's most
frequently requested and downloaded public
documents. Since January 1999, EPA has distributed
over 24,000 copies of the RCRA Generator, RCRA
TSDF, EPCRA and CERCLA Audit Protocols in
response to requests from the public.

The protocols can be obtained electronically via EPA's
Web site: http://www.epa.gov/oeca/ccsmd/
profile.html. The EPA Web site offers the protocols in
both pdf and MS-Word formats. For greater flexibility,
the word processing format allows the user to custom-
tailor the protocols to more specific environmental
aspects associated with the facility to be audited.

You can also obtain hard copies of the protocols by
contacting EPA's National Center for Environmental
Publication (NCEP) at 1-800-490-9198. When
ordering copies from NCEP, please reference the title
and the document number of the protocol(s) you' ve
selected.
Who Can I Contact for
More Information?

Richard Satterfield at the U.S. EPA
(202) 564-2456 or E-mail at
satterfield.richard@epa.gov
United States   '
Environmental
Protection- Agency
Office of Enforcement and Compliance Assurance
 EPA's
 Environmental

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      Regular environmental auditing of your facility
      is the cornerstone of any environmental
      management system (EMS). Environmental
audits allow facilities to manage their own
compliance by identifying: (1) where compliance is
being met; (2) potential areas for improvement;
(3) opportunities to correct deficiencies. The U.S.
Environmental Protection Agency (EPA) is
encouraging facilities to self-audit, and is developing
13 separate audit protocol guidebooks to encourage
this practice.

The audit protocols are designed for use by persons
with various backgrounds including scientists,
engineers, lawyers, and business owners or
operators. Environmental audit reports are useful to
a variety of businesses and industries, local, and
federal government facilities, as well as financial
lenders, and insurance companies, who need to
assess environment performance.

These protocols will provide detailed regulatory
checklists that you can customize to meet your specific
needs under the following 13 primary environmental
management areas:

  Generation of RCRA Hazardous Waste
  Treatment Storage and Disposal of RCRA
   Hazardous Waste
  RCRA Regulated Storage Tanks
  Universal Waste and Used Oil under RCRA
  Managing Nonhazardous Solid  Waste under RCRA
  Clean Water Act
  Safe Drinking Water Act
  TSCA
  Management of Toxic Substances
   (e.g., PCBs, lead-based paint, and asbestos)
  CERCLA
  Clean Air Act
  Pesticides Management (FIFRA)
  EPCRA
 How  will the  protocols
 help with  compliance
 issues  at  my  facility?

 "The Audit Protocols are invaluable as they provide
 easy-to-understand questions for evaluating compliance,
 and because they are available in a word processing
format. I can customize the checklists to our shipyard
facilities to make the audit most effective. Please keep
 up this very important service."
 —Thomas L. Stokes, Jr.,
  Stokes Environmental Associates, LTD.

 Each protocol summarizes key statutory requirements,
 defines regulatory terms and gives an overview of the
 federal laws affecting the respective environmental
 management area. The key feature of each protocol is
 the regulatory checklist containing detailed procedures
 for conducting a re view and audit of facility operations
 and conditions. The checklists outline performance
 objectives for the auditor and offer a line of inquiry
 when evaluating a facility for compliance. Each protocol
 contains the following information:

 • Guidance on the major facility activities and
   operations evaluated by the protocol and a brief
   description of how the protocol is to be applied;
 • A Regulatory Checklist which matches the
   regulatory requirements with the task that should be
   accomplished by the auditor;
 • A review of key federal legislation including key
   issues associated with the subject protocol area;
 • Typical issues normally addressed in state and local
   regulations;
 • Key compliance requirements - summarizes the
   overall thrust of the regulations for a given protocol
   topic;
 • Typical records to review during the course of the
   audit, highlighting documents, permits, and other
   pertinent paperwork that should be reviewed by an
   auditor and reconciled against regulatory
   requirements;
 I Typical physical features to inspect, highlighting
   pollution control equipment, manufacturing and
   process equipment and other areas that should be
   visited and evaluated during an audit;
 I A list of key compliance definitions, acronyms and
   abbreviations and other regulatory "terms of art"
   used in the federal regulations.
What if  I find a violation
while using  the
protocols?

EPA developed these protocols in support of
several EPA policies and programs, such as EPA's
Small Business Policy which is designed to promote
environmental compliance by providing compliance
assistance and incentives like penalty waivers to
eligible facilities with 100 or fewer employees. In
addition, the protocols were designed to encourage
businesses and organizations to perform
environmental audits and disclose violations in
accordance with EPA's Audit Policy. Like the Small
Business Policy, EPA's Audit Policy also offers
major incentives for eligible companies and other
organizations of all sizes to discover, disclose and
correct environmental violations.

These incentives can include the waiver of gravity-
based (punitive) penalties brought for violations that
are discovered through an environmental audit. If
you would like more information on EPA's Small
Business and Audit/Self-Disclosure Policies visit our
web site at: http://es.epa.gov/oeca/polguid/
polguidl.html or call EPA's Enforcement and
Compliance Docket and Information Center at
(202) 564-2614.

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