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
-------
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.
------- |