United States
Environmental Protection
Agency
Office of
Federal Activities
Washington, D.C.
cH A/130/4-89/001
August 1989
Environmental Audit Program
Design Guidelines
for Federal Agencies
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OFFICE OF FEDERAL ACTIVITIES
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
Environmental Audit Program
Design Guidelines for
Federal Agencies
August 1989
Printed on Recycled Paper
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NOTICE
These guidelines have been prepared with assistance from Booz.Allen & Hamilton Inc.
under two contracts, a draft under Contract Number 68-01-7378 and a final under Contract
Number 68-W8-0097, for the Office of Federal Activities, U.S. Environmental Protection
Agency. Mr. James R. Edward was the EPA Project Manager. The purpose of this document
is to provide technical assistance for environmental compliance auditing at Federal facilities and
is intended as a guide for auditing such facilities. The information and recommendations set
forth herein are intended as guidance to Government employees. It does not constitute
rulemaking by the EPA, and may not be relied on to create a substantive or procedural right or
benefit enforceable by any other person.
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ACKNOWLEDGEMENTS
This guidance was developed by James R. Edward of the Office of Federal Activities, U.S.
Environmental Protection Agency, and Barbara M. Young of Booz, Allen and Hamilton Inc,
Bethesda, Maryland. It is a pleasure to acknowledge the assistance of the following EPA staff
who kindly provided technical review: Kathy Hutson, Office of Federal Activities; Lee Braem,
Office of Enforcement and Compliance Monitoring; and Tapio Kuusinen, Office of Policy
Planning and Evaluation. Booz, Allen and Hamilton staff included Dr. Lyse Helsing, Donald
Gensler and Kathryn Wierman.
For further information or copies of these guidelines, please write to:
James R. Edward
Deputy Director
Federal Facilities Compliance Program
Office of Federal Activities (A-104)
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
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TABLE OF CONTENTS
CHAPTER 1 INTRODUCTION
A. Background
B. Purpose
C. Guideline Uses
D. Content
1
3
3
5
CHAPTER 2 UNIQUE ASPECTS OF FEDERAL FACILITY AUDITING
A. Agency Mission vs. Environmental Compliance 7
B. Management and Organizational Structure 8
C. Organizational Levels 9
D. Personnel Management 9
E. Budgeting and Appropriations Activities 10
F. Federal Agency A-106 Environmental Needs Plans 11
G. Contractor and Tenant Activities 11
H. Role of the States 12
I. National Security Concerns 12
J. Freedom of Information Act Requests 13
K. Federal Property Transfer Audits 13
L. Federal Facilities in the EPA Environmental Audit 14
Policy Statement
CHAPTER 3 ESTABLISHING AUDIT PROGRAM NEEDS AND OBJECTIVES
A. Parameters Affecting Program Objectives
B. Identifying Audit Program Needs
C. Identifying Audit Program Objectives
15
15
16
CHAPTER 4
THE FRAMEWORK OF AN ENVIRONMENTAL AUDIT
PROGRAM
A. Scope of an Audit
B. Developing Protocols
C. Structuring the Audit Team
D. Frequency of Audits
19
23
26
27
CHAPTER 5 IMPLEMENTING AN ENVIRONMENTAL AUDIT PROGRAM
A. Integrating Auditing with an Environmental
Management Program 31
B. Audit Program Organization and Delegation of Work. 34
C Funding an Environmental Audit Program 34
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CHAPTER 6 REPORTING RESULTS OF AN ENVIRONMENTAL AUDIT
A. Report Formats
B. Hierarchy of Reporting
C. Maintaining Confidentiality
CHAPTER 7 PROBLEM RESOLUTION
A. Assigning Priorities to Each Audit Finding
B. Audit Finding Tracking Systems
C. Follow-up Audits
D. Budgeting for Environmental Projects
E. The Federal Agency A-106 Environmental Needs,
Planning and Review Process
37
38
38
41
43
45
45
46
CHAPTER 8 EVALUATING AN ENVIRONMENTAL AUDIT PROGRAM
A. Technical Performance
B. Program Component Integrity
C. Environmental Compliance Results
49
50
50
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
ERA'S ENVIRONMENTAL AUDITING POLICY STATEMENT
FEDERAL AGENCY A-106 ENVIRONMENTAL NEEDS,
PLANNING AND REVIEW PROCESS
DEPARTMENT OF LABOR'S POSITION MANAGEMENT
AND ORGANIZATIONAL REVIEW
SMITHSONIAN INSTITUTION'S BUDGET PLANNING
SOURCES OF INFORMATION AND TRAINING
ANNOTATED BIBLIOGRAPHY ON ENVIRONMENTAL
AUDITING
11
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INTRODUCTION
The goal of environmental management is to reduce environmental pollution and minimize
risks associated with a facility's production, operations and maintenance. An environmental
management program oversees the environmental functions within an agency, generally providing
guidance and technical support throughout the entire organization. An environmental audit
program is a critical component of an agency's ongoing environmental management program.
Auditing increasingly is being used as a systematic method for verifying compliance with
applicable statutes and regulations, evaluating the effectiveness of environmental management
systems already in place, and identifying unregulated risks present at a facility. In essence,
environmental auditing provides the data for a facility or agency to prepare a "report card" to ensure
that the goals and objectives of their ongoing environmental program are achieved.
The Environmental Protection Agency (EPA) defines environmental auditing as a
systematic, documented, periodic and objective review of facility operations and practices related to
meeting environmental requirements (Exhibit 1-1). In addition, EPA policy encourages all Federal
agencies to develop auditing programs and offers technical assistance to help Federal agencies
design audit programs. This guidance document is one means by which EPA is following through
on its commitment to provide such assistance to other Federal agencies.
A. BACKGROUND
President Carter issued Executive Order 12088, Federal Compliance with Pollution Control
Standards, in 1978 in response to growing concern about environmental protection at Federal
facilities. The order requires Federal agencies to comply with all substantive and procedural
requirements of Federal, state and local environmental regulations. The EPA, in turn, is required
by the executive order to provide technical advice and assistance to ensure compliance by Federal
agencies. An important example of EPA's technical assistance is the Federal Facility Compliance
Strategy (referred to as the "Yellow Book") prepared in 1984 and revised in 1988. The strategy
establishes a comprehensive and proactive approach to achieving and maintaining high rates of
compliance at Federal facilities. It discusses in detail the importance of auditing as a compliance
tool that will assist agencies achieve high rates of environmental compliance.
On July 9, 1986, EPA issued a formal Environmental Auditing Policy Statement that
encouraged all regulated entities — private, municipal and Federal ~ to adopt environmental audit
programs (Appendix A). The policy statement stresses that although Federal law does not require
regulated entities to engage in auditing, the ultimate responsibility for environmental performance at
a facility lies with top management. Thus, managers have a strong incentive to use means such as
auditing to assess environmental compliance status. In addition, the policy statement contains a
separate section on environmental auditing at Federal facilities.
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EXHIBIT 1-1
EPA DEFINITION OF ENVIRONMENTAL AUDITING
Facility
Operations
and
Practices
To Assure
Meeting
Environmental
Requirements
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The policy also outlines seven elements considered to be the most important attributes of an
effective auditing program:
I. Explicit top management support for environmental auditing and commitment to
follow-up on audit findings
n. An environmental auditing function independent of audited activities
m. Adequate team staffing and auditor training
IV. Explicit audit program objectives, scope, resources and frequency
V. A method to collect, analyze, interpret and document information sufficient to
achieve audit objectives
VI. Specific procedures to promptly prepare candid, clear and appropriate written
reports and audit findings, corrective actions, and schedules for implementation
VII. Quality assurance procedures to ensure the accuracy and thoroughness of
environmental audits.
Consideration of these elements as they relate to Federal facilities will assist those Federal agencies
who are initiating their own audit programs or striving to improve existing programs. Exhibit 1-2
is a matrix showing where each of the seven elements of an effective auditing program is addressed
in this document
B. PURPOSE
The Office of Federal Activities (OFA) has developed the Environmental Audit Program
Design Guidelines for Federal Agencies in keeping with the spirit and intent of Executive Order
12088, the Federal Facilities Compliance Strategy and the Environmental Auditing Policy
Statement. The primary purpose of these guidelines is to provide information, criteria and
direction to Federal agencies who are designing environmental audit programs for facilities that
they own or operate. The Design Guidelines addresses concerns and considerations unique to
Federal agencies' environmental management activities. Considerations such as Federal
organizational and management structures, chain of command issues and Federal programming,
planning and budgeting systems are factored into this guidance.
OFA also has prepared the Generic Protocol for Environmental Audits at Federal Facilities,
which is a companion document to these guidelines. The Generic Protocol provides step-by-step
instructions for environmental problem identification at Federal facilities. It consists of a set of
narrative instructions, source lists, and checklists of Federal environmental regulations for all
environmental issues encountered at Federal facilities.
C. GUIDELINE USES
The Design Guidelines are intended to be used by Federal agency managers responsible for
environmental programs. In particular, this document is intended to provide a valuable starting
point for agencies which do not have an environmental audit program and should provide sufficient
guidelines to establish a program. The Design Guidelines are also structured to provide direction
to those agencies seeking to upgrade or expand their current audit program. Finally, for agencies
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EXHIBIT 1-2
Elements of Effective Environmental
Auditing As Addressed in Guidelines
Seven Elements of an Effective Audit Program
Guideline
Chapters
8
App A
AppB
AppC
App D
AppE
A
Exhibit 1,2
B,C
C,D
B
A,E,F,
K
A,B,C
A
Exhibit 1
V
B,D
Exhibit 1,3,4
J,H
A.B.C
Exhibit 1
A,B,D
A,B,C
Exhibit 1
Subheadings within each chapter
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with a comprehensive audit program, this document will provide a means to verify or enhance the
quality of the existing program. Because the Design Guidelines are written with the entire universe
of Federal agencies in mind, they are generic and may require adaptation with respect to the relative
complexity of environmental management needs within various Federal agencies.
D. CONTENT
The Design Guidelines contain eight chapters, each focusing on critical areas of audit
program design. This first chapter highlights the purpose of auditing, the historical context of
auditing in the Federal Government and defines the intended audience. Unique aspects of auditing
in the Federal Government are discussed in Chapter 2.
The remainder of the document follows a sequence of activities for starting or upgrading an
audit program. Chapter 3 addresses establishing audit program needs and objectives. The
development of a program's operational components is explained in Chapter 4. Implementing a
program is discussed in Chapter 5. The reporting of findings collected during an audit is discussed
in Chapter 6. Methods for correcting noncompliance are discussed in Chapter 7. Finally,
evaluating the effectiveness of an audit program is addressed in Chapter 8. Information considered
important but beyond the scope of the previously mentioned chapters is provided in several
appendices, which are listed in the Table of Contents.
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Chapters
Chapter 4
Chapters
Chapters
Introduction
Unique Aspects of
Federal Facility Auditing
Establishing Audit Program
Needs and Objectives
The Framework of an
Environmental
Implementing an
Environmental Audit Program
orting Results of an
Environmental Audit
Problem Resolution
Evaluating an
Environmental Audit Program
Appendices
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UNIQUE ASPECTS OF FEDERAL FACILITY AUDITING
This chapter highlights some of the unique considerations and issues encountered when
designing or upgrading an environmental audit program at a Federal agency. Approaches for
addressing each of these issues will be presented. These issues are inherent to Federal government
rather than to standard methods for problem solving. If not addressed, they may inhibit the design
of a program or affect the operations of an audit at a facility.
Some of the most important issues are:
Agency mission vs. environmental compliance
Management and organizational structure
Organizational levels
Personnel management
Budgeting and appropriations activities
Federal agency A-106 environmental needs plans
Contractor and tenant activities
Role of the State
National security concerns
Freedom of Information Act requests
Federal property transfer audits
Federal facilities in the EPA Environmental Auditing Policy Statement
Each of the above topics will be described, followed by a discussion of the pros and cons of
various approaches used by Federal agencies to resolve the problems created by the unique nature
of Federal facility audits.
A. AGENCY MISSION VS. ENVIRONMENTAL COMPLIANCE
The goals, objectives and responsibilities of each Federal agency are documented typically
in enabling statutes and each agency's mission statements. In addition, as a result of growing
environmental awareness, many agencies have a formal environmental policy statement. These
policy statements are often worded in broad terms and are subject to change as national priorities
change. For example, the following is an excerpt from the environmental policy statement of the
Department of Energy (DOE):
Protection of the environment and the public are responsibilities of paramount concern and
importance to this Department. All activities of DOE should recognize and reflect this
concern and public trust. To that end, DOE is firmly committed to assuring incorporation of
national environmental protection goals in the formulation and implementation of DOE
programs. It has an equal commitment to advance the goals of restoring and enhancing
environmental quality, and assuring public health. Accordingly, it is the policy of DOE to
conduct the Department's operations in compliance with the letter and spirit of applicable
environmental statutes, regulations, and standards. In addition, DOE is committed to good
environmental management in all of its programs and at all of its facilities in order to correct
existing environmental problems before they pose a threat to the quality of the environment or
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the public welfare. Finally, it is DOE's policy that efforts to meet environmental obligations
be carried out consistently across all operations and among all field organizations and
programs.
To be relevant and responsive to an agency's needs, it is very important that the audit program
objectives reflect the agency's mission and its internal environmental policies. (Chapter 3 provides
more details on establishing audit program objectives.)
The manager of an environmental audit program must clearly articulate the program
objectives for all elements of the agency's mission, and continually focus the organization towards
achieving the desired goals. For some agencies, such as Department of Interior and EPA,
environmental management is an integral part of their mission. The Army Corps of Engineers
(COE), by contrast, has potentially conflicting missions. For example, the COE may be directed to
provide flood control while at the same time required to protect endangered species. A major goal
of a Federal agency audit program is to increase understanding of environmental requirements so
the agency mission is accomplished in an environmentally sound manner; i.e., at a minimum,
achieving compliance with Federal, State and local regulations.
B. MANAGEMENT AND ORGANIZATIONAL STRUCTURE
The levels of authority and the delegation of responsibility through the management chain
of the Federal Government varies somewhat from the private sector. The principle organizational
difference in the Federal arena is the constraints put on an organizational structure via an agency's
Organization and Functions Statement. This statement must be reviewed when making changes in
an organization's structure. It may inhibit the flexibility necessary to address environmental
auditing issues. (Appendix B provides an example of the Department of Labor's organization and
functions statement.)
The levels of authority (chain-of-command) employed in the Federal sector are:
• Line personnel (mission operations managers) having responsibility, authority and
ultimately accountability for accomplishing program objectives. They can delegate
authority, but not responsibility. They determine the purpose of an action and allocate
resources needed for its accomplishment
• Staff personnel (technical specialists) having delegated technical authority by line
management to accomplish specific functions and achieve a specified performance
level.
In an audit program, line personnel establish policy, allocate resources for auditing and
commit to resolve problems found while auditing. Staff personnel carry out the policy and
auditing activities, as well as the corrective actions within their authority for functional areas.
Separating these duties is essential for oversight purposes and ensures unobstructed inquiry,
observation and testing.
The effective implementation of an audit program is not possible without strong support
and involvement of both line and staff personnel (Chapter 5 provides more detail on implementing
an audit program). Line personnel support should be demonstrated by an explicit written
commitment for the auditing program, provision of resources to conduct the program, and
budgeting tied to the Federal A-106 planning process (discussed below) to make corrective actions.
Staff personnel support, particularly at the audited facility, is essential to maintain a cooperative
and non-adversarial relationship between auditors and operators.
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Both line and staff offices initiate audit programs. Top line personnel may deem it
necessary because they are ultimately responsible and liable for the environmental performance of
their facilities and, thus, need to be kept up-to-date on environmental regulations and compliance
status, as well as provide oversight to their programs. An audit also may provide data for a
management information system for line offices. Staff offices may want a program because of
concerns over generic deficiencies in operations or inadequate internal compliance policies.
C. ORGANIZATIONAL LEVELS
Federal agencies are generally divided into national, regional and local offices.
Environmental compliance issues are most visible at the local level, and thus in the past, many
agencies have managed environmental compliance in a decentralized fashion. The technical
complexity of environmental laws and the extensive funding needed to correct violations and
underlying environmental problems now necessitates environmental management expertise at all
levels of an agency.
The status or organizational focus of an environmental audit program can be at any
organizational level. Options may include:
• National office audits at all agency facilities
• Local offices conducting self-audits, which are approved by national or regional offices
• A tiered process with national offices auditing all regional offices who in turn audit
local offices
• Local offices audit certain functions while the national or regional offices may audit
others.
The option chosen must ensure an auditor's objectivity and unobstructed inquiry,
observation and testing. A nationally managed audit program offers the advantage of uniform
standards. In addition, if there are national problems, an audit can be conducted of that particular
problem on a national basis. Locally managed audits offer the advantage of understanding of all
aspects of a facilities operations, but do not offer the degree of auditor objectivity afforded by
nationally managed audits. Drawing expertise from all three levels of an agency's organization
combines the best technical skills of its staff.
D. PERSONNEL MANAGEMENT
Audits conducted for Federal agencies may employ either civil servants, contract personnel
or a combination of both. There are advantages and disadvantages with using each for auditing
functions; however, financial and management issues will usually govern which type of auditors
are used at a particular agency.
When an audit program is structured using civil servants, the legal constraints of the civil
service system apply. In particular, personnel ceilings, or the number of Full Time Equivalents
(FTEs) available for a project can be a limitation. This may affect the extent if not the scope of the
audit program. On the other hand, the incentives and reward structure of the civil service,
especially at the managerial level, can be used to benefit the audit program. A civil servant's
performance can be directly linked to the agency's goals. If one goal is to meet environmental
requirements, the critical standards of performance ratings of line personnel could be based on
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progress in environmental compliance. This may encourage better compliance at all levels of
employment.
Use of contract personnel working on behalf of an agency is advantageous because it adds
objectivity to the audit process. A contracted company will not be impaired by personal
relationships, financial or other conflicts of interest with the agency or audited facility. (A
contractor will have to subcontract those audited facilities where a conflict of interest does arise.)
The lack of quality control is one disadvantage to such arrangements. Contractual agreements
should specify the level of technical expertise needed from the contractor and may even include the
resumes of auditors).
Some of the options in personnel management of an environmental audit program could
include:
• Full-time auditors at each facility
• Part-time auditors at each facility, selected from various divisions or operational units
• Oversight group with delegation of audit function to installation commanders or
operational units
• Oversight group with use of contracted auditors.
Further discussion of personnel management issues related to structuring Federal agency
audit teams is provided in Chapter 4.
E. BUDGETING AND APPROPRIATIONS ACTIVITIES
Assuring funding for environmental auditing programs and addressing audit findings
requires a through understanding of the Federal budget and appropriations process. The Congress
and Executive Branch, including the White House, Office of Management and Budget, and House
and Senate committees, are responsible for overseeing budget planning and appropriations for each
Federal agency. The agencies, through the President, must submit budgets to Congress. The
budgets are developed from meetings and discussions with agency national, regional and local
offices. An understanding of the timing of the key steps in the budget process is essential to the
success of an audit program. For example, the Smithsonian Institution's Office of Environmental
Management and Safety tracks the planning and budget schedule for the current year, budget year
and out-years as well as other relevant budget milestones, in order to ensure adequate funding for
their environmental program needs (Appendix C).
In addition to funding for the audit program, activities to correct environmental problems
found during an audit must be incorporated in a timely manner into all agency budget deliberations
and submissions. The results of an audit need to be known at various levels of the organization in
order to assure funding for corrective actions such as disposal costs, PCB transformer removal and
asbestos abatement. Such projects requiring capital expenditure often are considered "line-items"
in an agency's budget. Federal facility staffs need to build environmental costs into their facility
operations and maintenance (O & M) budgets. Environmental compliance needs to be recognized
as part of "the cost of doing business" in the government. An environmental audit program can be
an effective, independent means of identifying such needs and related costs so they can be
incorporation into Federal facility budget submissions.
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F. FEDERAL AGENCY A-106 ENVIRONMENTAL NEEDS PLANS
Executive Order 12088 and Office of Management and Budget (OMB) Circular A-106
require Federal agencies to submit Environmental Needs Plans, commonly called A-106 plans,
semi-annually to EPA's Office of Federal Activities for review. The plan should include funds
required for studies, environmental management and monitoring associated with the definition and
development of corrective actions and necessary equipment to adequately meet promulgated
environmental compliance deadlines. In addition, OMB issued an updated Circular A-l 1 in June
1988. This guidance strengthens the requirements for Federal facilities to coordinate with EPA,
via the A-106 plans, before budget estimates are submitted to OMB for design and construction of
pollution control and treatment projects. It clarifies that a project's budget should be consistent
with the latest agency plans submitted under OMB Circular A-106.
The A-106 process provides a mechanism for agencies to identify funds necessary to
correct problems identified in environmental audits. The audit program must coordinate with the
office responsible for the A-106 process. Within DOD, the Office of the Deputy Assistant
Secretary of Defense for Environment has published a handbook for understanding the A-106
process entitled "Federal Agency Pollution Abatement Plan (OMB A-106) Process," which is
available from U.S. Air Force Regional Civil Engineer/Central Region, 1114 Commerce Street,
Dallas, Texas 75242-0216, telephone (214) 653-3338. EPA also is developing a training course
and user's handbook on implementation of the A-106 process. Appendix B contains an EPA
summary description of how the A-106 process works.
G. CONTRACTOR AND TENANT ACTIVITIES
Identifying the Federal facility universe for the purpose of developing environmental audit
procedures is not necessarily a simple matter since agencies often have complex relationships with
private parties. Numerous Federal facilities and public lands have some level of private party
involvement in operating the facility or leasing a facility or lands for private use. The following
definitions describe a few of the contractor or tenant relationships encountered at Federal facilities:
• Government owned/contractor operated (GOCO) ~ a facility owned by a Federal
agency but operated by private contractors for government services
• Government owned/privately operated (GOPO) ~ a facility or lands leased by the
Federal Government to private operators for their own operation and profit
• Privately owned/Government operated (POGO) ~ a facility where the Government
leases buildings or space for its operations.
There are types of Federal facility arrangements other than those described above that may
affect the procedures and protocols of an audit. The EPA's Federal Facilities Compliance Strategy
provides a detailed discussion of these arrangements with private partners.
Whether or not the tenant or contractor activities are subject to an agency's environmental
audit program is influenced by a number of factors including:
• Statutory language as to who can be held responsible for completing regulatory
requirements
• Decisions made by the enforcement authority in deciding who the permit holder is or
who conducts monitoring
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• Established contractual arrangements specifying who is responsible for ensuring
compliance with applicable environmental statutes and regulations
• The nature and type of the activity in question.
An audit of contractor and tenant activities should not proceed until these issues are
reviewed thoroughly.
The traditional Federal facility (Government Owned-Government Operated (GOGO)),
where the Federal Government owns and operates all activities as one management entity,
simplifies an audit. A variation of this situation is common in the Air Force, when one major
command "owns" an Air Force base with another command as the major tenant. This relationship
is defined by an agreement delineating the rules and responsibilities as well as lines of
communication. It is similar to a contract agreement, but with subtle legal differences due to the
tenant being another Federal agency.
All landlord/tenant and contractor activities are bound by the terms of a host/tenant
agreement. The audit should not proceed until the agreement is thoroughly reviewed. Usually, it
specifies how the non-governmental entity is to operate and each parties' respective responsibilities
for ensuring compliance with applicable environmental statutes and regulations. For both parties'
protection, each should be aware of how the other intends to utilize land and/or buildings.
The status of who owns and operates the facility may affect the Federal Government's
liability for criminal and civil enforcement of environmental laws. The Federal Government has
less control when the audited facility is leased to (POGO) or from (GOCO or GOPO) the Federal
Government. In addition, contractual agreements are generally written that the Federal
Government reimburses the contractor or tenant operator for cleanup charges if the operation is in
compliance with the contract Servicing companies who are operating at Federal facilities and may
have a significant impact on the environment should also be audited. Even if a Federal agency
occupies a private facility, such as a GSA-leased facility, it is still responsible for auditing
operations and activities that may have an impact on the environment
H. ROLE OF THE STATES
EPA's Environmental Auditing Policy Statement encourages Federal agencies to submit
audit findings to EPA programs and delegated States "even when not specifically required to do
so." Federal agencies following this approach may find their audit programs subject to state
regulatory oversight A state's enforcement authority at a Federal facility found to be in violation
of a regulation is generally more extensive than EPA's. States, however, like EPA, may often
decide to pursue bilateral, negotiated agreements or have consent orders with Federal facilities
instead of using unilateral enforcement authorities and tools. In addition, the EPA auditing policy
encourages State and local regulatory agencies to adopt audit policies and approaches similar to
EPA's, "in order to advance the use of effective environmental auditing in a constant manner."
I. NATIONAL SECURITY CONCERNS
Federal facilities with military, intelligence, nuclear-related and law enforcement functions
frequently have special security requirements. Auditors must comply with security regulations for
access to these facilities and associated documents. This may mean providing adequate lead time to
obtain the necessary security clearances to conduct audits. Usually, secure areas and documents
can be protected to allow an audit to proceed without compromising national security. An internal
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audit program should be designed so adequate number of auditors have the necessary clearances
and so delays in conducting thorough audits are avoided.
J. FREEDOM OF INFORMATION ACT REQUESTS
The Freedom of Information Act, or FOIA, (5 USC § 552) applies to all Federal agencies.
Federal agencies are required to write their own regulations implementing FOIA. FOIA and the
agency regulations govern disclosures of audit reports or audit-generated information requested
from the agency by the public. Since draft audit reports and the auditors' preliminary notes may
contain personal thoughts and observations of the agency's environmental compliance, Federal
agencies may not want to disclose the contents of a draft report before they can be reviewed and
approved by the responsible parties in their agency (Chapter 6 provides more detail on report
preparation).
One item which is generally exempt from disclosure under FOIA is certain inter-agency or
intra-agency memoranda or letters (5 USC § 552 (b)(5)). This exemption is designed to protect
and encourage complete and forthright discussion of views within an agency concerning the
formulation of policies and decisions. In the past, some courts have protected documents which
show the agency's deliberative process in reaching decisions.
Because the deliberative process exemption usually applies to documents reflecting matters
of opinion or policy and does not exempt purely factual or scientific information, agencies may
want to consider separating audit reports into sections containing information that is: 1) clearly
releasable under FOIA (factual findings and scientific information) and 2) potentially releasable
(opinions, recommendations, and policy statements). It is likely that notes and working papers
prepared by an auditor in connection with the audit would not be exempt from release to the extent
they contain factual material.
To the extent draft copies of audit reports are pre-decisional in nature and show the
agency's deliberative process, they may be exempt from release. If particular factual material is
requested under FOIA, however, the agency may have to extract the material from the draft audit
report and release it to the requesting party. In order to protect draft copies within the deliberative
process, they should be clearly marked "draft" and circulation should be limited to offices or
audited facilities reviewing the report for final publication.
Legal advice from an agency's general counsel may provide additional help with handling
FOIA requests for audit-related information. In addition, each agency should consult their
regulations implementing FOIA. In any case, the effect of FOIA on audit-related information is an
issue Federal agencies should address when designing an environmental audit program.
K. FEDERAL PROPERTY TRANSFER AUDITS
Prior to selling its land to non-Federal parties or transferring property to other Federal
agencies, Federal agencies are required under § 120 (h) of CERCLA and its forthcoming
regulations to identify property on which hazardous substances (defined in CERCLA), not
hazardous waste, have been either released, disposed of, or stored for one year or more. The
statute applies to transfers of property by the Federal Government, and thus applies when property
is sold or ownership is transferred to another party, and not when the Federal Government
acquires property. The purpose of this legislation is to identify potential environmental problems.
If a problem is identified, than an investigation and testing follow, with a cleanup plan if needed.
The land is then transferred pending a successful cleanup. A proactive agency may ease the
13
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potential burden of the process by documenting the environmental status of its facilities in periodic
audit reports. In addition to the forthcoming regulations for CERCLA § 120 (h), EPA is planning
to develop general guidance for Federal agencies to use in conducting these Federal property
transfer audits.
L. FEDERAL FACILITIES IN THE EPA ENVIRONMENTAL AUDITING
POLICY STATEMENT
EPA issued its Environmental Auditing Policy Statement in the Federal Register on July 9,
1986 (51FR 25004). In addition to defining environmental auditing and encouraging all regulated
entities to audit, the policy contains a separate § HI, C, which is called "Environmental Auditing at
Federal Facilities." This section discusses a number of issues which are important to any Federal
agency designing an auditing program. As such, the entire text of the section has been excerpted
as follows:
EPA encourages all federal agencies subject to environmental laws and regulations to institute
environmental auditing systems to help ensure the adequacy of internal systems to achieve, maintain
and monitor compliance. Environmental auditing at federal facilities can be an effective supplement
to EPA and state inspections. Such federal facility environmental audit programs should be
structured to promptly identify environmental problems and expeditiously develop schedules for
remedial action.
To the extent feasible, EPA will provide technical assistance to help federal agencies design and
initiate audit programs. Where appropriate, EPA will enter into agreements with other agencies to
clarify the respective roles, responsibilities and commitments of each agency in conducting and
responding to federal facility environmental audits.
With respect to inspections of self-audited facilities and requests for audit reports, EPA generally will
respond to environmental audits by federal facilities in the same manner as it does for other regulated
entities, in keeping with the spirit and intent of Executive Order 12088 and the EPA Federal
Facilities Compliance Strategy, Federal agencies should, however, be aware that the Freedom of
Information Act will govern any disclosure of audit reports or audit-generated information requested
from federal agencies by the public.
When federal agencies discover significant violations through an environmental audit, EPA
encourages them to submit the related audit findings and remedial action plans expeditiously to the
applicable EPA regional office (and responsible state agencies, where appropriate) even when not
specifically required to do so. EPA will review the audit findings and action plans and either provide
written approval or negotiate a Federal Facilities Compliance Agreement. EPA will utilize the
escalation procedures provided in Executive Order 12088 and the EPA Federal Facilities Compliance
Strategy only when agreement between agencies cannot be reached. In any event, federal agencies are
expected to report pollution abatement projects involving costs (necessary to correct problems
discovered through the audit) to EPA in accordance with OMB Circular A-106. Upon request, and in
appropriate circumstances, EPA will assist affected federal agencies through coordination of any
public release of audit findings with approved action plans once agreement has been reached.
14
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-------
ESTABLISHING AUDIT PROGRAM NEEDS AND
OBJECTIVES
This chapter guides an agency in establishing the needs and objectives for an environmental
audit program. At this stage of design, an audit is simply an idea which needs to be turned into an
established program with defined objectives. The program objectives can best be selected if the
full spectrum of environmental needs particular to a Federal agency's overall mission and activities
are first carefully identified and evaluated.
A. PARAMETERS AFFECTING PROGRAM OBJECTIVES
Audit program objectives may be to verify and evaluate compliance status; ascertain
whether management systems are in place, adequate and functioning; address known
environmental risks; or develop greater environmental awareness and avoid potential problems.
Program objectives are selected based on not only identified needs but also within the context of
certain institutional parameters and other considerations:
• Urgency of addressing existing environmental problems
• Cost of an audit program
• Agency's public image
• Agency's overall environmental management program
• Expectations of senior management
B. IDENTIFYING AUDIT PROGRAM NEEDS
Careful identification of environmental needs is pivotal to the development of an adequate
environmental audit program or for upgrading an existing program. Needs to be addressed may
vary from agency to agency and must be examined within the context of each agency's mission and
activities. Factors to be considered may include:
• Environmental management policy
• Internal management practices and organizational structure
• Level of response required in short-term and long-term
• Budget constraints
• Facility operations.
15
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An agency should consider designing an audit program to:
• Reduce waste generated to lowest practicable levels
• Upgrade environmental awareness as a means to prevent environmental problems
• Detect potential environmental compliance problems
• Define more cost-effective measures to achieve environmental compliance
• Ensure adequacy of standard operating procedures
• Identify and address potential for cross-media impacts
• Improve environmental risk management systems by identifying conditions that could
have an adverse impact on the facility
• Assess level of risk associated environmental problems identified
• Train and motivate personnel to work in an environmentally acceptable manner.
In some cases, significant environmental problems may need to be identified before
effective and efficient auditing begins. For example, to focus its needs, the Department of Energy
conducted a one-time environmental survey to systematically catalogue and rank environmental
problems and areas of risk at department facilities. An audit program was then instituted after
completing the survey and analyzing the results.
C. IDENTIFYING AUDIT PROGRAM OBJECTIVES
Once an agency has defined the environmental needs to be addressed by their audit
program, the next step involves identifying short- and long-term objectives for the program.
Typical short-term objectives may be to:
• Verify compliance with laws and regulations
• Help facility management understand and maintain environmental compli ance
• Increase environmental awareness and help facility management understand regulatory
requirements
• Collect environmental baseline information
• Identify projects for A-106 Pollution Abatement Plans.
Long-term objectives may be to:
• Eliminate underlying environmental problems
• Discover conditions that may present serious risks or have an adverse impact on the
agency, personnel or the environment
• Evaluate effectiveness of the internal environmental management program
• Identify patterns of environmental problems among facilities.
16
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Not all of these objectives are suitable for every agency, but there are many advantages to
having a clear statement of at least a few objectives, which can be added to as the program
matures. They will define the functions of the audit and everyone's job in the organization. They
provide the basis for budgeting, as well as a movement toward determining the scope of the audit
program. Finally, audit program objectives are the start of any program's evaluation, covered in
detail in Chapter 8.
17
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Chapter 4
Chapters
|ue Aspects of
Federal Facility Auditing
Establishing Audit Program
Needs and Objectives
The Framework of an
Environmental Audit Program
; - " ^ -" '- \'\
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Implementing an '•*,:
Environmental Audit Program
Reporting Results of an
Environmental Audit
Problem Resolution
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m:^'^S^ I' Ihvirorjmeritar Audit Prfcgmrit
Appendices
-------
THE FRAMEWORK OF AN ENVIRONMENTAL AUDIT
PROGRAM
This chapter presents the basic framework for organizing an environmental audit program.
This will enable an agency to develop a program incorporating the essential components needed to
achieve program objectives. An audit can only be as good as the information it delivers and this
will depend on an agency making decisions about each of the following parts of the programs
organization:
• Scope
• Protocol development
• Audit team structure
• Frequency of audits
Each part is separately discussed below. Exhibit 4-1 presents a schematic overview of the audit
process. This will be a useful reference will organizing the parts of an agency's audit program.
A. SCOPE OF AN AUDIT
The concept of environmental auditing is still relatively new. The discipline is continuously
evolving and there is no strict or prescribed way to perform an audit. Nevertheless, whether an
environmental audit is limited or comprehensive in scope, it should reflect the multimedia nature of
pollution problems. Because the environment is a unified system within which pollutants cross
from one medium to another, pollution problems need to be addressed in an integrated or holistic
fashion, rather than as independent entities such as air, water, or land. To this end, a multimedia
environmental audit program is most effective in helping reduce environmental pollution and risks.
The EPA's Environmental Auditing Policy states that an audit can be designed to
accomplish any or all of the following: verify compliance with environmental requirements;
evaluate die effectiveness of environmental management systems already in place; or assess risks
from regulated and unregulated materials and practices. As Exhibit 4-2 illustrates, an audit
designed to verify compliance, Level I, is limited in scope in terms of environmental issues
covered. A program designed to cover all three levels of auditing activity would be more
comprehensive in scope. For example, an audit designed to review compliance with RCRA
regulations is focused on Level I, while a more comprehensive Level III program would likely
include review of a facility's hazardous waste handling standard operating procedures, and
assessment of the unregulated risks associated with hazardous waste management.
Initiating a new audit program aimed at all three levels of activity - compliance, management
and liability — may be too ambitious at first. EPA considers any one of these levels to be
acceptable in terms of meeting its basic definition of an acceptable audit program. Consideration
should be given to phasing in one level at a time. Using the following descriptions of
environmental audit activities, an agency can determine the program scope suitable to meet the
objectives of their environmental audit program.
19
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EXHIBIT 4-1
SCHEMATIC OVERVIEW OF THE AUDIT PROCESS
PRELIMINARY
OVERVIEW
GATHERING AUDIT
INFORMATION
EVALUATING AND
REPORTING
FACILITY
RETURNS
PRE-AUDIT
QUESTIONNAIRE
PRE-AUDIT
REVIEW
ENTRANCE
BRIEFING
FACILITY TOUR
• Photos
• Notes
CREATETEAM
AUDIT PLAN
DETAILED REVIEW OF
FACILITY PRACTICES
• In-depth Interviews
• Additional Tours
• Examine Records
\
/
EVALUATE INTERNAL
MANAGEMENT
CONTROLS
• Review SOPs
• Interview Facility
Management
\
/
DEVELOP
PRELIMINARY LIST
OF AUDIT FINDINGS
NIX
FURTHER
DISCUSSIONS AND
EXAMINATION TO
VERIFY FINDINGS
^
COMPLETE LIST OF
AUDIT FINDINGS
EXIT BRIEFING
WITH FACILITY
MANAGEMENT
PREPARATION OF
DRAFT AUDIT
REPORT
REVIEW OF
DRAFT REPORT
BY FACILITY
FINAL AUDIT
REPORT
W/CORRECTIVE
ACTION PLAN
20
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EXHIBIT 4-2
Levels of Environmental Audits
Verify
'compliance*
Evaluate the
effectiveness of
environmental
management system
Assess risks from regulated and
unregulated practices
21
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1. Level I: Regulatory Compliance Audit
Regulatory compliance audits do not in any way replace regulatory agency inspections;
however, this type of audit can improve compliance by verifying activities required by law.
Federal environmental regulations are found in the Code of Federal Regulations which is
published annually, or the Federal Register which is published daily. An audit should also
address'State environmental laws as well, even when they are more stringent or broader in scope
than the related Federal strategy. Typically included in an-audit program of this scope are:
• Air pollution control
• Water pollution control including wastewater discharge, groundwater monitoring and
drinking water
• Solid and hazardous waste management including PCBs, pesticides, asbestos and
radioactive material waste
• Past waste disposal practices
• Environmental impact assessment.
The importance given to each of these activities depends on the agency. A survey tided A
Review of Environmental Auditing Activities in Federal Agencies, OFA, February 1987, showed,
for example, that the Department of Defense, Department of Energy, U.S. Environmental
Protection Agency, National Institutes of Health, National Aeronautics and Space Administration,
and Tennessee Valley Authority have all established multimedia audit programs. Other
environmental audit programs are less comprehensive, i.e., the scope of the audits is focused on
one or more compliance areas. For example, the Department of Agriculture has established an
audit program addressing wastewater, underground storage tank, hazardous waste and CERCLA
requirements. The U.S. Coast Guard has established a program specifically tailored to audit for
RCRA requirements.
2. Level II: Management Audit
A management audit serves as a quality assurance check of basic environmental
management by verifying that management practices are in place, functioning and adequate. This
activity can be verified against successful management techniques used elsewhere in the agency,
or by other organizations. An environmental management audit can verify:
• Professional practices that promote or inhibit environmental compliance
• Standard operating procedures for various activities
• Established procedures for complying with EPA programs, e.g., NPDES discharge
monitoring or NEPA review
• The relationship of the environmental management function to ongoing activities at the
facility.
An audit team conducts a series of interviews, record reviews and a tour to develop an
understanding of the management systems in place at the audited facility. If a regulatory problem
has been verified, the management portion of an audit will focus on how the problem happened,
who is responsible for the cleanup and how much will it cost.
22
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3. Level III: Liability and Unregulated Risk Audit
The EPA's Environmental Auditing Policy recognizes that "auditing also can result in better
integrated management of environmental hazards, since auditors frequently identify environmental
liabilities which go beyond regulatory compliance." Whether regulated or unregulated, often the
most serious deficiencies identified during an audit are those threatening human health and the
environment. For example, used oil, not regulated under RCRA Subtitle C or in most State
regulations, could be handled, stored, and disposed of in a manner which poses potentially
serious, but unregulated, environmental and health risks. Federal agencies should seriously
consider eventually expanding audit program beyond the scope of the applicable regulations,
although, regulatory requirements usually are considered higher priority than nonregulatory issues.
Measuring the extent of environmental risk is a difficult task, with often the only definable
limits being hazardous and safe. If a decision is made to include environmental risk within the
audit scope, then potentially hazardous activities should be identified prior to the audit.
B. DEVELOPING PROTOCOLS
An audit program needs to have technical criteria for environmental problems to be
identified. Criteria also is needed so information gathered during an audit is sufficient, reliable,
relevant, useful and a sound basis for audit findings and recommendations. An audit protocol is
often used to fill this need. Protocols are a step-by-step instruction for who to talk to, what to look
for and questions to ask to identify environmental problems. Protocols are more than a mere
checklist for identifying compliance problems. Protocols are designed to provide detailed
instructions for qualified individuals to follow in conducting environmental audits.
The need for additions or enhancements to the Generic Protocol for Environmental Audits
at Federal Facilities, companion to this document, will vary according to the scope of an agency's
environmental audit program. The Generic Protocol provides a common framework for auditing
Federal facility regulatory requirements. Exhibits 4-3 and 4-4 contain examples of auditors'
instructions provided in the PCB Management chapter of the Generic Protocol. An agency
wanting to modify the protocol should take the following steps:
Step 1 - Determine media to be covered and priority topics within each medium based on
the scope and frequency of the audit
Step 2 - Identify and list Federal, State and local regulatory requirements. Revise the
protocol checklist to reflect what to audit at your facility
Step 3 - Review internal agency regulations, directives and standard operating procedures,
and decide which if any of these you want to add to the protocol
Step 4 - Identify any additional management issues or practices to audit
Step 5 - Revise the source list of records to review, physical features to inspect and people
to interview
In addition, an agency should plan on updating its protocol periodically to keep current
with audit techniques and new regulations.
23
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EXHIBIT 4-3
Example of Auditors' Source List From the Generic Protocol
AUDIT INFORMATION SOURCE LIST
Activity: PCB Management
Records to Review:
• Inspection, storage, maintenance and disposal records for PCBs/PCB items
• PCB equipment inventory and sampling results
• Correspondence with regulatory agencies concerning PCB noncompliance
situations
• Annual documents.
Physical Features to Inspect:
• PCB storage areas
• Equipment, fluids and other items used or stored at the facility that
contain PCBs.
People to Interview:
• Environmental Compliance Coordinator
• Facilities Manager
• Electrical Maintenance Staff.
24
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Activity: PCB Management
Regulatory
Citation
Auditors' Checklist
Comments
Finding
Number
m
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40CFR
761.65
ro
01
Storage of PCB Items for Disposal:
PCB items are inspected every 30 days for leaks.
PCB items are stored in DOT-approved containers.
Moveable equipment used to handle PCB items is
decontaminated prior to leaving storage area.
Stored PCBs and PCB items are disposed of
within one year from date they were placed in
storage.
Storage area is managed so that PCB containers can
be located by the date they are initially entered into
storage.
Long-term storage facilities (between 30 days
and one year) meet the following requirements:
- Roof and walls of the facility prevent rainwater
from reaching PCBs and PCB items
- The floor has continuous curbing (minimum 6
inches)
- The floor and curbing are made of continuously
smooth and impervious materials such as Port-
land cement or steel
-------
C. STRUCTURING THE AUDIT TEAM
The team conducting the audits is critical to the success of the overall environmental audit
program. Aspects to be carefully considered when assembling an audit team include skills and
training of team members, coordination of skills and responsibilities, and adequacy of staffing.
1. Prerequisite Skills and Training
Two sets of factors must be considered when assembling an audit team: the overall
expertise of the team and specific skills of individual team members. The audit team, as a group,
usually incorporates most of the following skills and expertise:
• Interest in and working knowledge of the various environmental pollution control
statutes and regulations
• Collective knowledge and experience in the efficient and effective conduct of all aspects
of a facility's management systems and control
• Skills in collecting information, gathering objective evidence, and diplomatic
interviewing.
Depending on the type of facility and purpose of the environmental audit, an individual
team member's professional background may include:
• Scientific or engineering expertise to understand manufacturing and production
processes, applicable pollution control technology for process effluents and waste types
generated
• Legal expertise to understand rules and regulations, including permits, registrations,
authorizations, monitoring and other requirements related to a specific facility
• Facility management and operations expertise to understand the type of facility being
audited, operations and processes being used
• Auditing expertise to understand audit procedures and verification techniques.
The use of personnel from many offices within an agency is possible when they are
properly briefed on the audited facility and are trained in the skills listed above. Training for
auditors should be ongoing and timely so audit procedures and techniques are kept current.
Training may be carried out at an inter-agency level to familiarize audit team personnel with
techniques, problems, and approaches developed and used in other agencies. Appendix D
discusses sources of training courses, seminars and University Certificate Programs. Appendix E
contains a bibliography for individuals interested in environmental auditing.
2. Team Coordination
The audit effort should be coordinated by a team leader with environmental audit expertise,
and a clear understanding of the type of facility to be audited, the type of audit to be performed,
and specific skills required from individual team members. The team leader also ensures that the
size of the audit team does not overwhelm the size of the facility and type of audit conducted. For
instance, it sometimes may be more efficient and no more costly to assemble a smaller team and
26
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take an additional day to cany out the audit, rather than assemble a larger team and sacrifice a good
relationship with the staff at the audited facility. The smaller team approach also may help
eliminate duplication of efforts by separate team members, and reduce the number of individuals
needing the attention of facility management.
The audit team leader and individual team members must develop and maintain a good
working relationship with facility personnel. The auditor has to allay the perception as an outside
intruder by setting a professional, courteous, and non-confrontational routine. Requests for
information should be direct and loose ends tied up before leaving the facility.
Depending on the type of facility and purpose of the audit, the technical and professional
skills of the team members will vary. For example, if the purpose of the audit is to verify that
procedures and policies are followed, people with experience in auditing and legal expertise are
good team members. If the purpose of the audit is liability assessment, the evaluation of the
environmental impact is more comprehensive and the audit team most likely would include people
with technical, engineering, legal, and auditing expertise.
3. Adequate Staffing
Adequate staffing of the audit team may be a serious problem that could delay the start of an
environmental audit program at many government agencies. Options to be considered for adequate
staffing of an audit team may include:
• Locating competent and qualified team members within the agency, such as the auditing
office of the agency, legal department, technical or engineering division; or
management staff from other facilities within the agency
• Using outside contractors for expertise not available internally
• Combining internal and external expertise to balance specific expert skills needed with
familiarity with environmental policies and management of the agency.
Larger organizations generally have greater resources to devote to an internal audit team while
smaller entities might be more likely to use contractors. If external support is used, some degree of
internal agency staff participation in the team will enhance the success of the audit. Agencies
should also consider what mix of headquarters, regional and field level staff will make up the
composition of the audit team. Some Federal agencies, for example, successfully include a
Headquarters representative on each audit team for oversight and program consistency purposes.
D. FREQUENCY OF AUDITS
There is no set frequency for auditing individual facilities. Auditing periodically, over
time, rather than a one-time occurrence, is preferred by EPA. Facilities may also want to consider
alternating an internal audit with any scheduled EPA or State enforcement inspections. The
frequency also depends on the facility type and takes into consideration three basic criteria listed
below and followed by a discussion of each:
• Environmental risk level
• Designation as a "major" or "minor" facility
• Staffing constraints.
27
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The survey of Federal agency audit programs mentioned earlier in this chapter shows that typically
a facility is audited every two to three years. These agencies include the Defense Logistics
Agency, the Department of Energy, the Environmental Protection Agency, the National Institutes
of Health, and the Tennessee Valley Authority. Other agencies, such as the Department of the Air
Force, the Department of the Navy, the Food and Drug Administration, and the Coast Guard
frequently vary auditing based on facility type and other criteria such as those discussed below.
1. Environmental Risk Level
The level and type of risks present at a facility are important criteria to help determine how
frequently an audit should be performed. The risk level is determined by several factors,
including:
Size of a facility
Geographic location of a facility, including proximity to population centers
Relationship to environmentally sensitive areas
Complexity of the activities and operations
Volume and characteristics of emissions, effluent, or stored materials
Whether problems of a serious nature have been found at the facility
Past compliance history.
For example, the potential risks associated with a facility using large volumes of highly toxic or
explosive materials are far greater and would warrant more frequent audits than at a facility housing
principally administrative functions where a simple initial audit may be adequate.
2. Major vs. Minor Facilities
Another factor to be considered when determining frequency of audits is whether an
installation is a "major" or "minor" facility (or equivalent terms) by EPA of State regulatory
authorities. This determination is based on rating criteria, emissions and effluent parameters, or
prior problems associated with the facility according to the various statutes and media programs.
(Note: The Office of Toxic Substances, responsible for implementing TSCA, does not categorize
facilities as major or minor.)
For example, under the NPDES permit program, an industrial water discharger is
categorized as major or minor by applying a numerical rating system based on five "rating criteria"
or characteristics:
Toxic pollutant potential
Flow/streamflow volume
Traditional pollutants
Potential public health impacts
Water quality factors.
Currently, a major NPDES facility is one that has been assigned 80 points or higher; all
facilities below 80 points are designated minor. For a municipal domestic sewage treatment plant,
a major facility services a population of 10,000 or more, discharges more than 1 million gallons
per day, or discharges into an environmentally fragile or "pristine" body of water. By contrast, a
minor facility does not meet these criteria.
28
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For air, a facility is considered a Class Al (major) stationary source if actual emissions, or
potential controlled emissions are equal to or exceed 100 tons per year of any regulated criteria
pollutant Class A2 facilities are stationary sources whose uncontrolled emissions operating at the
design capacity are equal to or exceed 100 tons per year for any regulated criteria pollutant, but
whose actual, potential or controlled emissions (whichever is greater) are less than 100 tons per
year. Class B (minor) facilities are any stationary sources with actual or potential uncontrolled
emissions of less than 100 tons per year.
Under the hazardous waste management program, designation as major and minor is based
on a facility's status as either a generator or a permitted treatment, storage or disposal facility
(TSDF), which EPA is required to inspect annually and is considered a major facility. More
specifically, the program further satisfies TSDFs as: High Priority Violators; i.e., those that merit
the most stringent and immediate enforcement because they have caused actual exposure, or there
is substantial likelihood of exposure to hazardous waste or hazardous constituents; Medium
Priority Violators, i.e., handlers with one or more Class I violations who do not meet the criteria
for a High Priority Violator; and Low Priority Violators, i.e., a handler who has only Class n
violations.
3. Staffing Constraints
The frequency of an audit at a given facility may be contingent upon the availability of
qualified personnel to conduct the audit. For example, the environmental audit program within a
given agency may require auditing of some 50 or more facilities, some of which may be fairly
large, with complex operations. If only two or three staff members are responsible for the auditing
task, it may be impossible to audit a facility as frequently as necessary unless additional internal
staff are assigned to the task. In such situations agencies may want to consider supplementing
agency audit personnel with qualified outside contractor assistance.
29
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si " ^ -N.^
Chapter
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Chapter2
Chapters
Chapter 4
Chapter 6
"'
r7
Chapters
/ jM/tf/tt ff * /
Introduction
Unique Aspects of
Federal Facility Auditing
Establishing Audit Program
Heeds and Objectives
The Framework of an
Environmental Audit Program
Implementing an
Environmental Audit Program
Reporting Results of an
Environmental Audit
Problem Resolution
Evaluating an
Environmental Audit Program
Appendices
-------
IMPLEMENTING AN ENVIRONMENTAL AUDIT PROGRAM
This chapter introduces methods for establishing and maintaining an environmental audit
program. Needs and objectives determination, discussed in Chapter 3, and program
administration discussed here, are often designed concurrently. Implementing an audit program
will require integrating auditing with an environmental management program, organizing and
delegating work, and budgeting for the program.
A. INTEGRATING AUDITING WITH AN ENVIRONMENTAL
MANAGEMENT PROGRAM
An audit program can be designed so at least some of its objectives match the mission of an
agency's or facility's environmental management program. Auditing can coordinate with the
following functions often found within an ongoing environmental program:
• Facility Technical Support -- The audit program provides information necessary for
guidance (policies, advisories and bulletins) that is prepared by the environmental
management program.
• Training ~ An audit leaves behind field personnel trained in regulatory requirements
and compliance assurance techniques.
• Budgeting and Procurement — An audit program provides independent data needed to
defend and support environmental budgetary requests to higher authorities.
Determining where the audit function belongs requires a thorough understanding of the
environmental management program within an agency. At some agencies, it may be possible to
extend auditing functions into existing "audit-type" programs such as an agency's inspector
general, instead of generating a new program. The most obvious homes for the audit function
are offices having missions related to occupational health, safety, environmental management,
planning, engineering, facilities and, in some agencies, auditing.. If these offices are an option, it
is useful to define in detail the coordination between the work conducted in each of them.
Exhibits 5-1 and 5-2 show where EPA and Tennessee Valley Authority (TVA) have located
audit programs in their organizations. These audit programs offer technical guidance, but not
management assistance, to the audited facility. At EPA, the Environmental Health and Safety
Division within the Office of Administration conducts environmental audits. At the TVA, the
Environmental Quality Staff in the Office of Natural Resources and Economic Development
conducts the audit program.
31
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EXHIBIT 5-1
Selected Portions of
EPA's Environmental Compliance Program
00
00
PROGRAM RESPONSIBILITY
LEGEND' i——
^— — UNE MANAGEMENT
A.^*~*AA_i_
i. : EATONAL ELEMENTS Beaignaled Agency C
HualHi andSafet
TONAL ELEMENTS 1
STRATrON
UGEMENT
iafrator
)ccupational
1 Official
OFFICE OF ADMINISTRATION
Director
Officer-kvCharge/Senior
Management Official
1
ENVIRONMENTAL HEALTH &
SAFETY DIVISION
Director
Agency Occupational Hearth & Safety
Officer/Senior Management Official
1
OCCUPATIONAL HEALTH &
SAFETY
Program Manager
:
1
ENVIRONMENTAL
COMPLIANCE
Program Manager
ENVIRONMENTAL PROTECTION
AGENCY
Adrranialrator
Offjcer-ivCharge/Senior
Management Official
OPERATIONAL RESPONSIBILITY
: —4,
OFFICE OF RESEARCH
AND DEVELOPMENT
Assistant AdmHetator
Ortcer-in-Charge/
Senfor Management Oficial
I
' '. ' - • if
OFFICE OF ENVIRONMENTAL
PROCESSES AND EFFECTS RESEARCH
Director
Officer-in-Charge/Senior
Management Official ^
PLANNING AND EVALUATION
STAFF
Director
Occupational Hearth and Safety
Deaignee
i
i
. I
.
1
f
EPA REGION 7
AunHiiaaalui
Officer-in-Charge/Senior
Management Official
f -
f ',
ENVIRONMENTAL SERVICES
DIVISION
Director
Officer-in-Charge/Senior
f
-/- 1
f- ,
1 '
ENVIRONMENTAL RESEARCH
LABORATORY
Laboratory Director
Cfficer-hvCharge/Senior
Management Official
Occupational
HeaHhand
Safety Deaignee
Environmental
Compliance
CoordRiator
J-»
CENTRAL REGIONAL
LABORATORY
Laboratory Director
Officer-in-Charge/Senior
Management Official *
Occupational Health and Safety
Deaig nee/Environmental Compliance
Coordrwtor
Laboratory
Operation
Field
Operalioita
I i
NOTE:
This EPA organizational chart depicts occupational health and safety/environmental compliance "program" and "operational" responsibilities. For clarity, only one of each Regional and Assistant Administrator
specific organizational element is shown. A dashed box represents other similar organizational elements, I.e., the other nine Regions. Bold lines between specific elements indicate line management channels,
while dashed lines indicate technical guidance, advice and support channels.
-------
EXHIBIT 5-2
The Auditing Function Within the Tennessee Valley Authority
ORGANIZATION OF THE TENNESSEE VALLEY AUTHORITY
Office of the
Inspector General
Office of Employee
Relations
Division of Personnel
Labor Relations Staff
Equal Opportunity
Staff
_L
Office of Natural Resource*
and Economic Development
Environmental Quality Staff
Industrial Development Staff
Air and Water Resources
Services and Held
Operations
Land and Economic Resources
BOARD OF DIRECTORS
OFFICE OF THE GENERAL MANAGER
_L
Office of
Government and
Public Affairs
Office of the
General Counsel
_L
Office of
Policy, Planning,
and Budget
_L
Office of
Corporate Services
Public Safety Service
Management Systems
Property and Services
Purchasing
Medical Services
Occupational Health
and Safety
Architectural and
Special Projects
Nuclear Manager's
Review Group
Nuclear Planning
& Financial Staff
Office of Power
Fossil and Hydro Power
Power System Operations
Operations Support
Conservation and
Energy Management
Energy Use and
Distributor Relations
Energy Demonstrations
and Technology
Power Engineering
and Obstruction
_L
Officeof
Agricultural and
Chemical Development
Research
Technology
Development
Developmental
Production
Agricultural
Institute
33
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B. AUDIT PROGRAM ORGANIZATION AND DELEGATION OF WORK
An audit program may be managed either through headquarters, if the program is agency-
wide, or through a regional office or major command overseeing facilities within its jurisdiction.
Major design decisions such as setting objectives, scoping and budget requirements are usually
delegated to the following environmental program staff:
• Environmental Management Program Senior Manager -- responsible for approving the
audit program, approving audit procedures, notifying facility/activity of pending audits,
transmitting audit reports to audited facility and the associated Headquarters -- level
representative; maintains official file copy of audit report
• Environmental Audit Program Manager -- responsible for administering the
environmental audit program
• Lead Auditor -- responsible for planning and leading specific audits and heading up
audit teams
• Facility Environmental Compliance Coordinator — responsible for managing the
environmental management program for senior officials at the facility and maintaining
Federal, State and local regulations and agency records related to the program.
An audit program functions independently from line personnel but also relies on their
strong support. Support from key personnel at each level of an agency's operational line
personnel is essential for the program's success. The role of line personnel in the audit process
is:
• Senior Government Official at the audited facility — responsible for providing the
facility background information and the follow-up on deficiencies, including a remedial
action plan
• Regional Program Manager (in some agencies there is not a regional presence in which
case the corresponding oversight would report to headquarters) — responsible for
ensuring that funds are made available for remedial actions (may request assistance
from headquarters for funding)
• National Program Director — generally located in agency headquarters and ultimately
responsible for the facility's environmental compliance.
Auditing provides mutual benefit for both compliance program staff personnel and line
personnel. The line personnel will receive verification of their facility environmental needs and
accomplishments through the audit process. In return, this verification can assist line managers
in overall program development and management, and specifically with obtaining the resources
(money and people) necessary to correct significant deficiencies. For an audit program to be
successful, senior line managers (to whom even the audit program staff may report) must accept
environmental compliance as part of the cost of doing business, i.e., as part of achieving the
agency's overall mission.
C. FUNDING AN ENVIRONMENTAL AUDIT PROGRAM
Funding is needed for environmental audit program activities, including engineering design
and decisions, people, travel, clerical, graphics and management support. Funding can come
34
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from two sources: 1) an agency's existing funding or 2) "fenced" money. Existing program
funding includes:
• Operation and maintenance funds
• Mission funds of the programs using the audited facility
• Overhead accounts
• Research and development money.
The disadvantage of funding an audit program from existing program money is the possible
conflict of interest. Programs supporting the audit effort will have a vested interest in the audit
results. The advantage, however, is that auditing costs are shared by those programs most in
need of the auditing service. This funding mechanism also supports the principle of
environmental compliance as a cost of doing business.
The alternative funding mechanism is to establish a "fenced" account for environmental
auditing. Separate funding for auditing is more difficult achieve because it is perceived as money
received at the expense of other projects and programs throughout the agency; however, it has the
distinct advantage of eliminating competition for funding between the auditor and facility or
program managers.
35
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Chapter 4
Chapters
Chapters
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f t f f S *s Sjff Y f's St ft
A * f'ffj" fff t ffe f fJfff f f-
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^ introduction
Unique Aspects of
Federal Facility Auditing
Establishing Audit Program
Heeds and Objectives
The Framework of an
Environmental Audit Program
x. Implementing an
Environmental Audit Program
Reporting Results of an
Environmental Audit
Problem Resolution
Evaluating an
Environmental Audit Program
Appendices
-------
REPORTING RESULTS OF AN
ENVIRONMENTAL AUDIT
This chapter describes what an audit report should, be designed to communicate to the
audited facility and agency management. For purposes of this discussion, it is assumed an audit
has been completed and has resulted in a wealth of information that must now be managed.
Depending on the scope of the audit, reports will include regulatory compliance findings,
assessment of conditions warranting management attention, and observations of nonregulated
activity that may present health or environmental risk, such as lack of agency policy, substandard
agency practices and potential noncompliance. Reports may also note exceptionally positive
aspects of environmental management.
A. REPORT FORMATS
Audit reports must be compiled in a manner useful to both the staff and line personnel.
Consideration should be given to reporting formats. The choices of format for reporting the
results of an audit include an oral report, written report and automated report. Each of these
formats is useful at different times. A report in any format, should include at a minimum: the
date of the audit, the auditors names, a facility description, a description of each problem found,
a regulatory citation (if applicable), a statement of how to correct the problem, and a priority for
doing so.
The audit team may present their results verbally during an audit exit-briefing at the audited
facility. The oral report simply is a temporary substitute for a written document. The purpose of
this oral report is to verify the conditions noted by the audit team and give facility staff the
opportunity to refute findings proposed for the written report. This review also helps to avoid
inaccuracies in the written report. Ideally, the oral report should be presented by the audit team to
the senior government official at the facility (e.g., base commander, lab director, etc...).
Written results of the audit are drafted by the audit team. A determination of who in the
agency will review and edit the report should be made prior to the audit program commencing.
Methods must be determined for resolving all differences and documenting why changes are
made to original findings. As an audit program matures and audit procedures are refined, the
circle of reviewers can decrease. The final audit report is a summary of findings and
recommendations grouped by major environmental areas. Deficiencies should be ranked in
priority order (Chapter 7 provides more detail on ranking). It will lend credibility to the report if
it is transmitted with the signature of the senior management official in the agency's
environmental management organization.
It is very important that the reader of the audit report readily understands what the auditor
has to say. Audit reports must be well written. The following writing tips can improve an audit
report:
* The writing must be clean and concise — do not use buzz words, jargon or
unnecessary acronyms. Avoid long sentences and use paragraphs to separate issues.
37
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Be as factual and specific as possible. Use numbers to quantify and dates to verify.
Avoid general phrases such as "a number of excursions were noted" when the
specific number can be given. Avoid interjecting opinion or inflammatory comments.
Do not write in the first person. Rather than using pronouns such as "I "and "we",
use words such as "the auditors found" or "the audit team observed."
To the extent possible, use the active voice, putting the subject of the sentence first,
then what happened. This tends to be more descriptive and less wordy.
A computer-generated audit report is usually one of several capabilities of an automated
tracking system such as the one described in Chapter 7. Once the audit data is stored in the
computer, a well designed system is capable of analysis, record keeping, and compliance
tracking as well as report generation. Exhibit 6-1 illustrates a page from EPA's audit program
computer-generated audit report. The computer produced reports are more uniform and readable,
which lends credibility to the program as a whole. As this form of reporting becomes more
sophisticated, the device can even become part of the audit team, with data entry taking place at
the audited facility. Automation should be a goal of all audit programs, however, a year or two
of written reports may give the reporting format the time needed to evolve into what is desired in
the form of computer produced reports.
All background data and working papers used to generate an audit report should be retained
for reference until the report has been acted on. The audit program may want to establish a
formal policy in this regard, such as retaining the files for a year, or until a subsequent audit is
conducted. Existing agency policies in the area also may govern retention of audit background
information and working papers.
B. HIERARCHY OF REPORTING
A hierarchical scheme may be used for distributing the audit findings. The first step is to
identify the levels of the line management with authority over the facility. In general, reports
should become more generalized as their circulation moves higher up the chain-of-command.
Senior officials at the audited facility should be provided a copy of the complete final report
which may have highly detailed, location-specific narratives. Associated headquarters-level
representatives may receive the final report or may request abridged reports or executive
summaries. Graphic presentations of agency-wide trends of regulatory compliance may be the
most effective reporting mechanism within the agency or for the public.
Draft audit reports also need a distribution plan for review and comment. It is usually
beneficial to allow the audited facility the opportunity to review the draft report for accuracy,
although an agency may choose not to include actual recommendations in the draft report for
facility review. In general, a report should be finalized and distributed only after small problems
are fixed and larger violations are scheduled for remedial action.
C. MAINTAINING CONFIDENTIALITY
An audit can generate significant amounts of sensitive information. The audit team should
thus make their observations, findings or recommendations as objective as possible. Report
distribution may be limited to those people with a "need to know". It is also wise to keep
38
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EXHIBIT 6-1
Example of a Computer-Generated Audit Report
Toxic Substances Control Act
does not own and is not responsible for any PCB
transformers or PCB-contaminated electrical equipment (photograph
28). is, however, conducting research that uses PCB-
containing standards and samples and that generates waste for
which PCB regulations apply.
Regulatory Findings
Priority B
Finding Number: 42
Several PCB containers at are not marked with
the appropriate PCB warning labels in accordance with
TSCA regulations. PCB containers used to collect waste
in Room 411 must have a PCB marking if the contents
contain greater than 50 ppm PCBs. PCB stock solutions
stored in Room 170 also must be marked with the PCB
warning.
Regulatory Citation: 40 CFR 761.40
*
Finding Number: 43
PCB research conducted in Room 170 is not an activity
authorized under 761.30(j). Therefore must seek
approval for this research, as outlined in 40 CFR Part
761.60(i)(2), from EPA's Region V Regional
Administrator.
Regulatory Citation: 40 CFR 761.60(02
Priority C
Finding Number: 44
The information in the 1987 Annual PCB document is
incomplete. Although the document PCB items such as
transformers, it failed to include the PCBs used in
research as part of the total quantities of PCBs on-
site.
Regulatory Citation: 40 CFR 761.180A
23
39
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Internal audits of the nature described throughout this document are not necessarily
required to be provided to regulatory agencies or state authorities. In EPA's Environmental
Auditing Policy Statement (Appendix A), however, Federal agencies are encouraged "... to
submit audit findings and remedial action plans expeditiously to the applicable EPA regional
office (and responsible State agencies where appropriate) even when not specifically required to
do so." This policy also describes EPA's broad statutory authority to request relevant
information on the environmental compliance status of regulated entities. EPA's policy, however,
states they will not routinely request environmental audit reports because routine requests for
audit information may inhibit auditing in the long run.
The auditing policy statement contains a critical discussion of this confidentiality issue which
is important to consider in designing a Federal agency audit program. As such, the following is an
excerpt from § HI A of the policy statement:
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' to generate the data. Thus, this policy does not
alter regulated entities existing or future obligations to monitor, record or report information
required under environmental statutes, regulations or permits, or to allow EPA access to that
information. Nor does this policy alter EPA's authority to request and receive any relevant
information ~ including that contained in audit reports ~ under various environmental statutes
(e.g., Clean Water Act § 308, Clean Air Act § 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.
In addition, Federal agencies should be aware that the Freedom of Information Act will
govern any disclosure of audit reports of audit-generated information to the public. Chapter 2 -
Freedom of Information Act Requests ~ has a more detailed discussion. The desire to retain the
confidentiality of audit results may necessitate precautions while preparing and distributing the
final audit report. If top management supports the audit program and has made a commitment to
promptly correct problems, the sensitivity of the audit results will be minimized.
40
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Federal Facility Auditing
Needs and Objectives
Chapter4
- -
Tlt« Framework of m "l
Environmental Audit Program
: I: . Implementing
Environmental
Reporting Results of an
Environmental AtidJt
Problem Resolution
Evaluating an
ronmental Audit Program
-------
PROBLEM RESOLUTION
This chapter describes features that can be added to a program to encourage the correction
of environmental problems found during an environmental audit. A single environmental audit
may discover many and diverse findings. In an audit report, each finding is broken down into a
description of the problem and a clear statement of what action would correct the finding. For
example, the audit team found chronic spillage on the ground around an underground storage
tank as a result of overfilling. This violates RCRA underground storage tank regulations. The
problem is a lack of supervision during tank filling, improper equipment, and noncompliance
with regulatory requirements.
Recommending appropriate responses to this problem is the responsibility of facility
management. They may respond to a findings of noncompliance with a remedial action plan. A
remedial action may vary in detail, depending on the priority of the finding. For example, the
Bureau of Prisons requires an individual, itemized response to "significant findings," but allows
a blanket response to all findings which are "policy deviations." A plan often will delineate one
or more remedial action milestones.
Facility management will be constrained by many factors, such as competing budget and
staff commitments, environmental technical uncertainties, relative priority of existing facility
requirements, lack of staff support, or insufficient oversight of the audit program. Problem
resolution at the facility is more likely and repeat violations may be avoided if an agency develops
a method to assign a priority to each audit finding, track remedial actions, and budget and plan
for their environmental compliance.
A. ASSIGNING PRIORITIES TO EACH AUDIT FINDING
To complete the audit process and have a useful report to return to the audited facility, the
findings must be analyzed and recommendations for remedial action clearly stated for easy
implementation. The usefulness of an environmental audit to some extent depends on the
methods used by both the auditors and line management to categorize and rank audit findings.
For maximum benefit, the audit team needs to report the priority of findings in a manner useful to
management responsible for remedial actions. Agreement on method before the audit program
begins will avoid the facility having to rank the findings when the report is received for action.
1. Categorizing Type of Audit Finding
Findings may be categorized to help structure the audit report and rank remedial actions.
Categorizing schemes may also be useful when choosing a reporting hierarchy, as discussed in
Chapter 6. Findings may be grouped according to:
• Regulatory finding
• Agency policy
• Professional practice
• Local conditions/public perceptions.
41
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Selective use of broad categories to group findings will help set priorities. Depending on the
scope and depth of the audit, findings may be presented as subcategories within categories. For
example, under the category "Regulatory Finding," there may be such subcategories as training,
record keeping, and permit or license violations. Another useful method for subcategorizing
findings is to divide each category by process; i.e., procedural deficiencies such as absence of
required paper work, or equipment deficiencies, such as no fire extinguishers.
2. Setting Priorities
Methods for assigning priority to a finding may be a simple decision tree or a more
complex matrix with assigned point factors. The methods used should incorporate the following
criteria:
• Promotes consistent application
• Addresses factors of interest to management
• Documents priority designation.
Use of priority schemes assist audit program managers in designing subsequent audits and status
reviews or help identify changing conditions, for example, more low priority findings with
decreasing high priority findings over time. A priority scheme also assist in using audit reports
to evaluate the effectiveness of the overall agency environmental compliance program.
Both auditors and line management must define the basis for determining priorities. A
priority code can be a simple list of the findings in descending order of priority or within the
category. Agency managers may rank findings according to:
• Authority establishing the requirement, such as Federal and State laws, regulations,
permits, interagency agreements; or agency environmental management program
• Probability and severity of hazard identified and its effect on human health and the
environment
• Reporting requirements and potential enforcement penalties associated with a finding.
One other possible means for assigning priorities to audit findings is to use EPA's
compliance classification scheme for the A-106 Environmental Needs Planning and Review
Process. The A-106 process is a system of setting priorities so environmental control projects
are completed as required to meet statutory and regulatory requirements. There are never enough
funds available to complete all desired projects in one fiscal year. The A-106 process programs
projects over five-year period. The primary focus of the process is to give the highest priority to
projects needed for facilities that are out of compliance or will go out of compliance if the project
funding schedules are not met. This process establishes a hierarchy of nine different compliance
categories divided into three distinct classes.
Class I
EPA places its highest priority on Class I projects. These projects are needed at Federal
facilities which are in physical noncompliance and/or have received an enforcement action from
EPA or a State. The following three categories are included in Class I:
• CMPA Projects needed to support a signed Compliance Agreement or Consent Order.
42
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• INOV - Projects needed to correct deficiencies cited on an inspection or Notice of
Violation (NOV) by a regulatory authority.
• ESDP - Other projects which are required immediately because a statutory or regulatory
deadline has passed.
Class II
Class II projects are considered next in priority by EPA. These projects are needed at
facilities which are not yet out of compliance, but will be if not implemented prior to certain
regulatory deadlines in the future. Class II projects are the most difficult to budget for because
the compliance dates are in the future and standards may still be in the process of being
established. Nevertheless, if Federal agencies delay, it is likely they will be out of compliance
when the deadlines arrive. Class II projects make up a substantial part of Federal agency
requirements and are divided into two categories:
• ESDF - Projects for facilities that do not meet established standards, but the compliance
deadline is in the future.
• PSDF - Projects for facilities where a pending standard cannot be met and the
compliance deadline is in the future.
Class III
Class HI combines a potpourri of situations that are of less importance to EPA at the
present time but that may be important compliance and management issues in the future, if not
implemented. While of less importance to EPA, they may be a very high priority to other Federal
agency. This class includes the following:
• ERSO - Facility meets established standard but needs replacement because of
obsolescence.
• ESRE - Facility meets established standard but needs expansion or will go out of
compliance.
• ESDL - Facility meets established standards but project is needed for other than
compliance reasons. Will demonstrate leadership.
• OTHR - Other reasons not falling in categories described above.
B. AUDIT FINDING TRACKING SYSTEMS
Instituting an automated tracking system should be a long-term objective of any successful
audit program. Too frequently, deficiencies cited during an audit are not corrected because they
"fall through the crack." A computer system for tracking audit status and facility remedial actions
may help ensure that problems are corrected on-time and within budget. The benefits of an
effective tracking system to assist managers are:
• Specific future actions occur as scheduled
• A record is maintained documenting when an action was fixed
43
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• The present status of an action may be determined
• Incomplete remedial actions may be added to future audits.
1. Need for Tracking
IA tracking system may be needed to record remedial action milestones, remind the facility
of scheduled actions and record when a finding is fixed. Few major remedial actions can be
started without addressing the requirements of other activities at the facility. In addition,
unscheduled events may cause budget conditions to change, requiring reallocation of funds. A
tracking system that includes the finding priority and the cost of the remedial action enhances the
long-term success of an audit program.
2. Developing and Maintaining a Tracking System
An audit tracking system should store the information necessary to manage the remedial
action. Unless kept to the minimum essential information, tracking systems may grow into
unwieldy and costly management information systems. An audit tracking system normally
includes items such as:
Description of finding
Date of audit that uncovered the problem
Responsible manager
Audit responsible for finding
Description of remedial action
Milestones in remedial action plan
Estimated resources ($, FTE) to properly address problem
Finding priority
Status.
No single tracking system is suitable for all Federal agencies. A tracking system may be as
simple as a card file rather than a sophisticated computer-assisted management information
system.
To be an effective management tool, the system should be operated by trained personnel,
following a standardized operating procedure (SOP). The SOP should provide for:
• When the finding is entered
• Who confirms the addition or deletion of a rinding
• Who reviews summaries of missed milestones
• How records are distributed, safeguarded, verified, maintained, backed-up, and
changed.
The SOP must meet the needs of the manager responsible for the remedial action.
44
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C. FOLLOW-UP AUDITS
The need for follow-up audits, or remedial action verification, is related to the facility's
overall environmental compliance status or the degree of agency oversight of the facility.
Follow-up audits may be conducted depending upon several factors, including:
Degree of noncompliance
Relative importance of ensuring problem has been fully corrected
Extent of repeat noncompliance issues
Technical expertise necessary and available at the facility to handle the cited deficiencies
Audit team's ability to assist in implementing remedial actions.
Even though the presence of an audit team tends to highlight agency management's concern
for environmental compliance, the follow-up audit should be used primarily as an opportunity to
assist the facility in correcting an underlying environmental problem. For example, a visit to
assist the technical staff in handling a complex remedial action or to ensure a finding was
correctly interpreted by the facility, can be beneficial and should be conducted. Incomplete
remedial actions may, however, be included in the next scheduled audit.
If an activity has a history of repeat findings and the facility is recalcitrant in addressing the
findings, follow-up audits are not the answer. In this case the agency has a facility management
problem that must be addressed and resolved through line management channels. This situation
may also require the intervention of someone located sufficiently high in the chain-of-command
to compel resolution of the problem.
D. BUDGETING FOR ENVIRONMENTAL PROJECTS
Federal facility managers are sometimes faced with lengthy delays for correcting an
obviously non-compliant situation. This is because, with the exception of de minimis findings,
e.g., changes in records management or posting of signs, most remedial actions require
significant capital expenditures. If an environmental problem does require significant capital
expenditures, the agency can consider reprogramming funds, transferring authority, or
requesting a supplemental appropriation that will enable them to receive funds in the year in
which they are needed.
When a remedial action has a low priority within the present fiscal year budget, it becomes
an unfunded requirement and is usually programmed into future budget years. The time required
to approve and secure funding for such a remedial action generally depends upon such
considerations as:
Need for the project
Type of project
Funding level required
Compliance status or extent of enforcement
Other agency approval authority over the project
Extent of enforcement or agency approval authority over the project
Category of expenditure
Associated documentation required for the project.
An audit report can help defend the funding request. It provides both independent field notes on
the situation at hand and a regulatory citation.
45
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Latitude for reallocating appropriated resources is generally quite constrained at the field
level of an agency. In some cases, such as facility construction, the local facility management, or
even the agency, may not have authority to approve the reallocation of resources. The facility
will thus have to enter the remedial action into the formal budget process used by the agency.
Budget planning can cover up to five years, with changes becoming less likely as the out-years
get closer to the current fiscal year. When the remedial action involves construction, several
years may be required to prepare environmental impact documentation required before costs are
entered into the budget process.
Even when a facility has taken each of the necessary steps to secure funding for a remedial
action, the project may not be approved. One of the more common reasons for disapproval is
that the project is not included in the A-106 planning process. OMB has access to an agency's
A-106 plan and verifies the need for an environmental project contained in an agency budget
request by cross-checking to see if the project is presented in the A-106 report.
E. THE FEDERAL AGENCY A-106 ENVIRONMENTAL NEEDS,
PLANNING AND REVIEW PROCESS
All projects identified as a result of an environmental audit should be incorporated in an A-
106 plan. The A-106 plan is the common name given for thevprocess pursuant to Executive
Order 12088 requiring each Federal agency to submit pollution abatement/environmental needs
plans to OMB through the Administrator of EPA. The purpose of this process is to :
• Ensure Federal agencies are funding environmental requirements
• Inform OMB of environmental project funding requirements
• Allow agencies to use the Federal Agency Pollution Abatement Plan (A-106 Report) as
a management plan for compliance with environmental requirements
• Provide EPA with a basis for Pollution Status Reports for use in connection with the
Federal Facilities Compliance Program
• Identify backlogs of unfunded projects
• Forecast unfunded requirements arising as a result of new statutory/regulatory
requirements.
The A-106 report is not a budget request document. It simply provides OMB with a means
to compare an agency's annual and supplemental budget requests with the environmental
problems documented in the report. For this reason, the A-106 process should record any
remedial action identified through an environmental audit and should serve as a useful
complementary tool for the audit program. The information provided through completion of the
OMB A-106 reporting process will help a facility to:
• Support the funding and staffing needs of environmental projects and program
requirements
• Document efforts to address compliance problems identified through audits
• Operate a proactive environmental management program
46
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Track regulatory compliance costs
Manage liabilities
Make top management accountable for environmental compliance.
47
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Unique Aspects of
Federal Facility Auditing
Establishing Audit Program
Needs and Objectives
The Framework of an
Environmental Audit Program
f mptementtng an
Environmental Audit Program
Reporting Results of an
Environmental Audit
Resolution
Evaluating an
Environmental Audit Program
Appendices
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EVALUATING AN ENVIRONMENTAL AUDIT
PROGRAM
The seventh and final element of effective environmental auditing outlined in the EPA's
Environmental Auditing Policy is the need for a quality assurance component in an audit
program. Element VQ suggests that an effective environmental audit program will likely have "a
process which includes quality assurance procedures to assure the accuracy and thoroughness of
environmental audits. Quality assurance may be accomplished through supervision, independent
internal reviews, or a combination of these approaches."
This chapter presents some methods for evaluating the quality and effectiveness of an
environmental audit program. These methods will be most useful If established early in the
program development when quality control authority and responsibility is delegated. Program
evaluation and quality assurance can be continuous but is particularly valuable after completing a
distinct phase of the audit task. The important point is that in designing an environmental
auditing program, Federal agencies should build in a component that periodically evaluates the
effectiveness of the program. The evaluation of an audit program may focus on the following
three functions:
• Technical performance
• Program component integrity
• Environmental compliance results.
A. TECHNICAL PERFORMANCE
Technical work is evaluated by examining data collection and report writing. The quality
objectives of each is described below.
1. Data Collection
The data collected during the audit should be appropriate to the scope of the audit, be as
complete as possible, be traceable to their source and be comparable among all individuals
involved in the audit. Appropriate and complete data collection requires a well-briefed and
trained audit team. Traceable and comparable data can be controlled through standards for
auditors' conduct, i.e., both what is asked and how it is asked. Audit protocols set the standards
for what is asked. How questions are asked can be controlled by the auditor keeping the
following points in mind:
• Applicability to the activity
• Effectiveness of meeting the requirements
• Reasons for deficiencies
• Ways to rectify the situation.
49
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2. Report Writing
The quality of a written document can be judged by whether it presents technically accurate
information, addresses objectives of the audit and is organized in a clear, consistent and logical
manner. This can be assured by establishing audit team technical review meetings to review
documents, and by soliciting written comments from the audited facility.
B. PROGRAM COMPONENT INTEGRITY
All of the components of the audit process including establishing objectives, audit team
staffing, conducting the audit and reporting results, should be relevant to the needs of the audited
facility and to the environmental management program. This requires the informed judgement of
the audit program staff to promote the evaluation of each component and to resolve issues and
concerns that lie ahead.
An agency can build a process by which objectives are developed and their attainment
evaluated. That process should be suited to the organization. One method is to distribute an
audit appraisal questionnaire to audited facilities. An example of the Tennessee Valley
Authority's appraisal form is shown in Exhibit 8-1. A second method is for the auditors or a
larger group from the program to evaluate the process. The auditors' opinion is valuable when
updating protocols, and determining the prerequisite skills of the team and the frequency of audits
for a specific activity.
C. ENVIRONMENTAL COMPLIANCE RESULTS
EPA recognizes that measuring environmental results can be a difficult task, but feels
some attempt to do so should be part of all audit programs. The number and magnitude of
environmental problems identified during an environmental audit can be used to evaluate a
program's success. If evaluated over time, analyses of the following audit results and trends
may be valuable:
• Regulatory compliance rates based on each environmental media
• Regulatory compliance rates based on assigned priorities
• Number of regulatory compliance deficiencies identified
• Average facility regulatory compliance rates.
A successful environmental audit program should be reflected in increased regulatory
compliance rates on a Federal agency-wide basis. The compliance rate of a single environmental
issue could be the focus of a program quality review. Where a distinction is made between major
and minor violations, an audit program may have more minor violations with decreasing major
violations over time. A Federal agency also might want to measure success by the number of
significant violations identified or enforcement actions that are taken by EPA or State regulatory
agencies at their facilities. While no one measure or report may be solely attributable to the audit
program, there still should be a direct relationship between an environmental management
program's overall success or failure and the effectiveness of the audit program. Finally, overall
improvement in regulatory compliance should result from an audit program that successfully
identifies a facility's or an agency's generic patterns of noncompliance and addresses them
effectively.
50
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EXHIBIT 8-1
Tennessee Valley Authority's Audit Appraisal Questionnaire
Environmental audits are conducted by EQS to inform you and the management of your facility, the
General Manager, and the General counsel of the status of environmental compliance at your
facility with regard to applicable Federal, State, and local environmental laws and regulations
and TVA environmental policies and procedures. While this connotes a policing or oversight
function, we view our objectives and role to be one of service to you by providing an
independent evaluation of the status of environmental compliance at your facility. We want to
let you know how you are doing in complying with environmental requirements. In short, we are
not in the business to criticize, embarrass or find fault, but rather to work with you to help
TVA attain an exemplary environmental compliance track record.
We are very interested in constructive criticism regarding the effectiveness of the audit
program and would like you to complete the attached questionnaire. If the questionnaire does
not address your concerns, feel free to list them under "Comments." Please return the
questionnaire to the Director of Environmental Quality. Thank you.
Your
Name:
Position:
Organization/Facility:
Dates of audit visit: from to
Indicate the extent to which you agree or disagree with the following statement by circling the
appropriate code, as fellows:
SA = Strongly agree D = Disagree
A = Agree SD = Strongly disagree
UD - Undecided NA = Not applicable
Audit Planning
1. I was given a clear indication of the scope and
purpose of the audit before commencement. SA A UD D SD NA
2. I was given a clear indication of who would
receive copies of the report after completion. SA A UD D SD NA
3. The auditors were prepared and knowledgeable. SA A UD D SD NA
Audit Conduct
4. The audit staff was overly concerned with
unimportant or immaterial detail checking. SA A UD D SD NA
5. The audit did not result in excessive dis-
ruption to the operation of this facility. SA A UD D SD NA
6. This audit was conducted in a professional
manner. SA A UD D SD NA
51 July 21, 1986
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Audit Staff
7. Audit staff had sufficient knowledge and under-
standing of the work and system of this
facility. SA A UO D SO NA
8. Audit staff had sufficient technical skills
and experience. SA A UO D SD NA
9. Audit staff showed a good awareness of current
events relevant to this facility. SA A UD 0 SD NA
10. Audit staff showed a good awareness of current
events relevant to this facility. SA A UD D SD NA
11. Audit staff showed interest and enthusiasm for
their job. SA A UO D SD NA
12. Audit staff was adequately supervised. SA A UO D SD NA
Communication of Results
13. Audit report was factual and accurate. SA A UD D SD NA
14. Audit report contained adequate explanation for
the findings and recommendations. SA A UD D SO NA
15. There was adequate discussion of the audit
report between the auditors and the management
of this facility at the exit meeting. SA A UD 0 SD NA
16. Audit report was unduly concerned with trivia. SA A UD D SD NA
17. Audit report was useful to the management of
this facility. SA A UD D SO NA
18. I would recommend that the environmental com-
pliance audit program audit this facility
again. SA A UD D SD NA
19. If answer to number 18 is yes, how often do you
feel your facility should be audited? Once/Yr. Once/18 mo.
Once/2 Yrs. Once/3 Yrs.
Comments:
(Use back of questionnaire if necessary)
July 21. 1986
52
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Unique Aspects of
Federal Facility Auditing
Establishing Audit Program
Needs and Objectives
The Framework of an
Environmental Audi! Program
Implementing an
Environmental Audit Program
Reporting Results o! an
Environmental Audit
Problem Resolution
; Evaluating an
Environmental Audit Program
Appendices
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ERA'S ENVIRONMENTAL AUDITING POLICY STATEMENT
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Federal Register / Vol. 51. No. 131 / Wednesday. July 9. 1966 / Notices
ENVIRONMENTAL PROTECTION
AGENCY
(OPPE-FRL-3046-6)
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
unregulated environmental hazards.
EPA first published this policy as
interim guidance on November 8.1985
(30 FR 46504). Based on comments
received regarding the interim guidance.
the Agency is issuing today's final
policy statement with only minor
changes.
This final policy statement
specifically:
• Encourages regulated entities to
develop, implement and upgrade
environmental auditing programs;
• Discusses when the Agency may or
may not request audit reports:
• Explains 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 auditing includes a
variety of compliance assessment
techniques which go beyond those
legally required and are used to identify
actual and potential environmental
problems. Effective environmental
auditing can lead to higher levels of
pverall compliance and reduced risk to
human health and the environment. EPA
endorses the practice of environmental
auditing and supports its accelerated
use by regulated entities to help meet
the goals of federal, state and local
environmental requirements. However.
Jhe_existence of an auditing program
does not create any. defense to, or
otherwise limit, the responsibility of any
regulated entity to comply with
applicable regulatory requirements.
States are encouraged to adopt these
or similar and equally effective policies
in order to advance the use of
environmental auditing on a consistent,
nationwide basis.
DATES: This final policy statement is
effective July 9.1986.
FOR FURTHER INFORMATION CONTACT:
Leonard Fleckenstein, Office of Policy.
Planning and Evaluation, (202) 382-
2728;
or
Cheryl Wasserman. Office of
Enforcement and Compliance
Monitoring. (202) 382-7550.
SUPPLEMENTARY INFORMATION:
ENVIRONMENTAL AUDITING
POLICY STATEMENT
I. Preamble
On November 8.1985 EPA published
an Environmental Auditing Policy
Statement, effective as interim guidance.
and solicited written comments until.
January 7,1988.
Thirteen commenters submitted
written comments. Eight were from
private industry. Two commenters
represented industry trade associations.
One federal agency, 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 provisions as remedies
in enforcement actions, one addressed
environmental auditing at federal
facilities, and one addressed the
relationship of the policy statement to
atate 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 policy 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 policy on the whole to
be constructive, felt that 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 environmental
auditing programs—the "incentives"
most frequently mentioned in this
context—are fraught with legal and
policy obstacles.
Several 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 believes
that the interim guidance effectively
encourages voluntary auditing. In fact.
Section II.B. of the policy states:
"because audit quality depends to a
large degree on genuine management
commitment to the program and its
objectives, 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 limitations. 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 only part of a successful
environmental management program
and thus should not be expected to
cover every environmental issue or
solve all problems. EPA agrees and
accordingly has amended the statement
of purpose which appears at the end of
this preamble.
Yet another commenter thought EPA
should focus on environmental
performance results (compliance or non-
compliance), not on the processes or
vehicles used to achieve those results. In
general. EPA agrees with this statement
and will continue to focus on
environmental results. However. EPA
also believes that such results can be
improved through Agency 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 sponsor
seminars for small businesses on how to
start auditing programs. EPA agrees that
such seminars would be useful.
However, since audit seminars already
are available from several private sector
organizations. EPA does not believe 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 / Vol. 51. No. 131 / Wednesday. July 9. 19B6 / Notices
25005
provide technical assistance for
environmental compliance.
Requests for 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
privacy, and allowing the Agency
enough flexibility of inquiry to
accomplish future statutory missions.
However, most commenters expressed
concern that the interim guidance did
not go far enough to assuage corporate
'cars that EPA will use audit reports for
environmental 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
willing 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 clarify that a request for an
audit report or a portion of a report
normally will be made when needed
information is not available by
alternative means. Therefore, EPA has
revised Section II1.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 Agency."
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
III.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 even 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 focused on particular
information needs rather than the entire
report," to the second sentence of
paragraph two. Section III.A.
Incorporating the two comments above,
the first two sentences in paragraph two
of final Section III.A. now read: "EPA's
authority to request an audit report or
relevant portions thereof, will be
exercised on a case-by-case basis where
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 than 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 has 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
statutory 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 final policy
statement should remain largely
unchanged from the interim version.
Elements of Effective Environmental
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
expand or more fully detail these
auditing elements.
.Another commenter asserted that
states and localities should be cautioned
not to consider EPA's auditing elements
as mandatory steps. The Agency is fully
aware of this concern and in the interim
guidance noted its strong opinion that
"regulatory agencies should not attempt
to prescribe the precise form and
structure of regulated entities
environmental management or auditing
programs." While EPA cannot require
state or local regulators to adopt this or
similar policies, the Agency does
strongly encourage them to do so. 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 very 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
not 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
second paragraph of section III.B.l. of
the interim guidance which states that
environmental audits can 'complement'
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
lacking. 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 same commenter also expressed
concern that as EPA sets inspection
priorities, a company having an audit
program could appear to be a 'poor
performer' due to complete and accuraU
reporting when measured against a
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Federal Register / Vol. 51. No. 131 / Wednesday. July 9. 1986 / Notices
company which reports something less
than required by law. 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 change 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
facilities when other factors may be
overriding. Therefore the policy
statement continues to state that EPA
ni«> 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 final commenter suggested the
phrase 'expeditiously correct
environmental problems" not be used in
the enforcement context since it implied
EPA would use an entity's record of
correcting nonregulated matters when
evaluating regulatory violations. EPA
did not intend for such an inference to
be made. EPA intended the term
"environmental problems" to refer to the
underlying 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
Federal Facilities Compliance Strategy.
which is referenced in section III. C. of
the auditing policy. The Strategy should
'be completed and available on request
from EPA's Office of Federal Activities
later this year.
EPA thanks all commenters for
responding to the November 8.1985
publication. 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
regulated entities to institutionalize
effective audit practices as one means of
improving compliance and sound •
environmental management, and (b)
guide internal EPA actions directly
related to regulated entities'
environmental auditing programs.
EPA 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
systematic, documented, periodic and
objective review by regulated entities '
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 environmental management systems
already 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. However.
environmental 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 of effective auditing
programs to help achieve and maintain
compliance. Additional information on
environmental.auditing practices can be
found in various published materials.*
1 "Regulated enlitiea" include private firm* and
public agencies with facililiei subject to
environmental regulation. Public agencies can
include federal, itate or local agencies ai well at
special-purpose organiialions such as regional
sewage commissions.
* See. e.g.. "Current Practices in Environmental
Auditing." EPA Report No. EPA-230-OB-B3-OOB.
February 1984: "Annotated Bibliography on
Environmental Auditing." Fifth Edition. September
1985. both available from: Regulatory Reform Staff.
PM-223. EPA, 401 M Street SW. Washington, DC
20460.
Environmental 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 employed 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, survey, 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 Encourages the Use of
Environmental 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 internal systems to achieve.
maintain and monitor compliance.
Implementation of environmental
auditing programs can result in better
identification, resolution and avoidance
of environmental problems, as well as
improvements 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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25007
performance of the facility 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
been widely 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. EPA Policy on Specific
Environmental Auditing Issues
A. A??, ~y 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
policy. EPA will not routinely request
environmental audit reports.
EPA's authority to request an audit
report, or relevant portions thereof, will
be exercised on 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 likely
focused on particular information needs
rather than the entire report, and usually
made where the information needed
cannot be obtained from monitoring.
reporting or other data otherwise
available to the Agency. Examples
would likely include situations where:
audits are conducted under consent
decrees or other settlement agreements:
a 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 "environmental audit report" i> • written
report which candidly end thoroughly preienti
finding* from a review, conducted a* part of an
environmental audit at described In wet ion M.A.. of
facility environmental performance and practice!.
An audit report ia not a »ututitute for compliance
monitoring report! or other report! or record! which
may be required by EPA or other regulatory
ayvnciei.
is illustrative rather than exhaustive.
since there doubtless will be other
situations, not subject to 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'
to generate that data.4 Thus, this policy
does not alter regulated entities' existing
or future obligations to monitor, record
or report information required under
environmental statutes, regulations or
permits, or to allow EPA access to 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 to 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.
Regulatory agencies have an
obligation to assess source compliance
status independently and cannot
eliminate inspections for particular firms
or classes of firms. 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
establish minimum facility inspection
frequencies to which EPA will adhere.
However. EPA will continue to
address environmental problems on a
priority basis and will consequently
inspect facilities with poor
environmental records and practices
more frequently. Since effective
environmental auditing helps
management identify and promptly
correct actual or potential problems.
audited facilities' environmental
performance should improve. Thus.
while EPA inspections of self-audited
facilities will continue, to the extent that
compliance 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 environmental
problems. When regulated entities take
reasonable precautions to avoid
noncompliance. expeditiously correct
underlying environmental problems
discovered through audits or other
means, and implement measures to
prevent their recurrence. EPA may
exercise its discretion to consider such
actions as honest and genuine efforts 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 decrees
and in other settlement negotiations
where auditing could provide a remedy
for identified problems and reduce the
likelihood of similar problems recurring
in the future.5 Environmental auditing
provisions are most likely to be
proposed in settlement negotiations
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 regulated
entity.
* See, for example. "Dutiei to Report or DUclota
Information on the Environmental Aipectl of
Busineii Activitlet." Environmental Law Inililute
report to EPA. final report. September 1985.
* EPA ia developing guidance for uae by Agency
negolialori in structuring appropriate environmental
•udit proviiioni for conaenl decrees and other
settlement negoliatloni.
A-4
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25008
Federal Register / Vol. 51. No. 131 / Wednesday. July 9. 1986 / Notices
Through this consent decree approach
und other means. EPA may consider
how to encourage effeclivc auditing by
publicly owned sewage treatment works
(rams). POTWs often have
compliance problems related to
operation and maintenance procedures
which can be addressed effectively
through the use of environmental
auditing. Under its National Municipal
Policy EPA already is requiring many
POTWs to develop composite correction
plans to identify and correct compliance
problems.
C. Environmental Auditing at Federal
Fwlities
EPA encourages all federal agencies
subject to environmental laws and
regulations to institute environmental
auditing systems to help ensure the
adequacy of internal systems to achieve.
maintain and monitor compliance.
Environmental auditing at federal
facilities can be an effective supplement
to EPA and state inspections. Such
federal facility environmental audit
programs should be structured to
promptly identify environmental
problems and expenditiously develop
schedules for remedial action.
To the extent feasible, EPA will
provide technical assistance to help
federal agencies design and initiate
audit programs. Where appropriate. EPA
will enter into agreements with other
agencies to clarify the respective roles,
responsibilities and'commitments of
each agency in conducting and
responding to federal facility
environmental audits.
With respect to inspections of self-
audited facilities (see section II1.B.1
above) and requests for audit reports
(see section II1.A above). EPA generally
will respond to environmental audits by
federal facilities in the same manner as
it does for other regulated entities, in
keeping with the spirit and intent of
Executive Order 12088 and the EPA
Federal Facilities Compliance Strategy
(January 1984. update forthcoming in
late 1986). Federal agencies should.
however, be aware that the Freedom of
Information Act will govern any
disclosure of audit reports or audit-
generated information requested from
federal agencies by the public.
When federal agencies discover
significant violations through an
environmental audit. EPA encourages
them to submit the related audit findings
and remedial action plans expeditiously
to the applicable EPA regional office .
(and responsible state agencies, where
appropriate) even when not specifically
required to do so. EPA will review the
audit findings and action plans and
either provide written approval or
negotiate a Federal Facilities
Compliance Agreement. EPA will utilize
the escalation procedures provided in
Executive Order 12088 and the EPA
Federal Facilities Compliance Strategy
only when agreement between agencies
cannot be reached. In any event, federal
agencies are expected to report pollution
abatement projects involving costs
(necessary to correct problems
discovered through the audit) to EPA in
accordance with OMB Circular A-106.
Upon request, and in appropriate
circumstances, EPA will assist affected
federal agencies through coordination of
any public release of audit findings with
approved action plans once agreement
has been reached.
IV. Relationship to State or Local
Regulatory Agencies
State and local regulatory agencies
have independent jurisdiction over
regulated entities. EPA encourages them
to adopt these or similar policies, in
order to advance the use of effective
environmental auditing in a consistent
manner.
EPA recognizes that some states have
already undertaken environmental
auditing initiatives which differ
somewhat from this policy. Other states
also may want to develop auditing
policies which accommodate their
particular needs or circumstances.
Nothing in this policy statement is
intended to preempt or preclude states
from developing other approaches to
environmental auditing. EPA encourages
state and local authorities to consider
the basic principles which guided the
Agency in developing this policy:
• Regulated entities must continue to
report or record compliance information
required under existing statutes or
regulations, regardless of whether such
information is generated by an
environmental audit or contained in an
audit report. Required information
cannot be withheld merely because it is
generated by an audit rather than by
some other means.
• Regulatory agencies cannot make
promises to forgo or limit enforcement
action against a particular facility or
class of facilities in exchange for the use
of environmental auditing systems.
However, such agencies may use their
discretion to adjust enforcement actions
on a case-by-case basis in response to
honest and genuine efforts by regulated
entities to assure environmental
compliance.
• When setting inspection priorities
regulatory agencies should focus to the
extent possible on compliance
performance and environmental results.
• Regulatory agencies must continue
to meet minimum program requirements
(e.g., minimum inspection requirements.
etc.).
• Regulatory agencies should not
attempt to prescribe the precise form
and structure of regulated entities'
environmental management or auditing
programs.
An effective state/federal partnership
is needed to accomplish the mutual goal
of achieving and maintaining high levels
of compliance with environmental laws
and regulations. The greater the
consistency between state or local
policies and this federal response to
environmental auditing, the greater the
degree to which sound auditing
practices might be adopted and
compliance levels improve.
Dated: June Z8,1986.
Lee M. Thomas,
Administrator.
Appendix—Elements of Effective
Environmental Auditing Programs
Introduction: Environmental auditing
is a systematic, documented, periodic
and objective review by a regulated
entity of facility operations and
practices related to meeting
environmental requirements.
Private sector environmental audits of
facilities have been conducted for
several years and have taken a variety
of forms, in part to accommodate unique
organizational structures and
circumstances. Nevertheless, effective
environmental audits appear to have
certain discernible elements in common
with other kinds of audits. Standards for
internal audits have been documented
extensively. The elements outlined
below draw heavily on two of these
documents: "Compendium of Audit
Standards" (61983, Walter Willborn.
American Society for Quality Control)
and "Standards for the Professional
Practice of Internal Auditing" (1981,
The Institute of Internal Auditors. Inc.).
They also reflect Agency analyses
conducted over the last several years.
Performance-oriented auditing
elements are outlined here to help
accomplish several objectives. A general
description of features of effective,
mature audit programs can help those
starting audit programs, especially
federal agencies and smaller businesses.
These elements also indicate the
attributes of auditing EPA generally
considers important to ensure program
effectiveness. Regulatory agencies may
use these elements in negotiating
environmental auditing provisions for
consent decrees. Finally, these elements
can help guide states and localities
considering auditing initiatives.
A-5
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Federal Register / Vol. 51. No. 131 / Wednesday. July 9. 1986 / Notices
25009
An effective environmental auditing
system will likely include the following
general elements:
I. Explicit top management support for
environmental auditing and
commitment to follow-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 well
as federal, state and local statutes and
regulations.
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 activities. 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.
III. Adequate team staffing and
auditor training. Environmental 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 audit 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 facility:
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, analyzes.
interprets and documents information
sufficient to achieve audit objectives.
Information should be collected before
and during an onsite visit regarding
environmental compliance^),
environmental management
effectiveness^?), 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
recommendations.
a. Sufficient information is factual.
adequate and convincing 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 quality
assurance procedures to assure the
accuracy and thoroughness of
environmental audits. Quality assurance
may be accomplished through
supervision, independent internal
reviews, external reviews, or a
combination of these approaches.
Footnotes to Appendix
[]) A comprehensive assessment of
compliance with federal environmental
regulations requires an analysis of facility
performance against numerous
environmental statutes and implementing
regulations. These statutes include:
Resource Conservation and Recovery Act
Federal Water Pollution Control Act
Clean Air Act
Hazardous Materials Transportation Act
Toxic Substances Control Act
Comprehensive Environmental Response.
Compensation and Liability Act
Safe 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 government are
likely to have their own environmental laws.
Many states have been delegated authority to
administer federal programs. Many local
governments' building, fire, safety and health
codes also have environmental requirements
relevant to an audit evaluation.
(2) An environmental audit could go well
beyond the type of compliance assessment
normally conducted during regulatory
inspections, for 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 net
specifically addressed in regulations:
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
environmental 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 parties working for, with or
on behalf of the organization to follow its
environmental procedures:
A-6
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25010 Federal Register / Vol. 51. No. 131 / Wednesday. July 9. 1966 / Noticet
6. Make proficient personnej^ available at
all time* to carry out envfmifHMfal
(especially emergency) procedures;
7. Incorporate environmental protection
into written operating procedure!:
8. Apply beet management practices and
operating procedures, including "good
housekeeping" techniques;
9. Institute preventive and corrective
maintenance systems to minimize actual and
potential environmental harm:
10. Utilize best available process and
control technologies:
11. Use most-effective sampling and
monitoring techniques, test methods.
recordkeeping systems or reporting protocols
[beyond minimum legal requirements);
12. Evaluate causes behind any serious
environmental incidents and establish
procedures to avoid recurrence;
13. Exploit source reduction, recycle and
reuse potential wherever practical: and
14. Substitute materials or processes to
allow use of the least-hazardous substances
feasible.
(3) Auditors could also assess
environmental risks and uncertainties.
|FR Doc. B6-15423 Filed 7-8-86 8:45 am]
BILLING CODE SSSO-W-M
A-7
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A PORTION OF DEPARTMENT OF LABOR'S POSITION
MANAGEMENT
AND ORGANIZATIONAL REVIEW
-------
MANAGEMENT OPERATIONS
DLMS 3
CHAPTER 2000 - POSITION MANAGEMENT AND ORGANIZATIONAL REVIEW
Paragraph
2000
2001
2002
2003
2004
2005
Contents
INTRODUCTION TO POSITION MANAGE-
MENT AND ORGANIZATIONAL REVIEW
Purpose
Scope
Objectives
Relationship to Department
Management Systems
Definitions
20-1
20-1
20-1
20-1
20-2
20-2
2010
2011
2012
2013
AUTHORITY, POLICY, AND
RESPONSIBILITIES
Authority
Policy
Responsibilities
20-4
20-4
20-4
20-4
Z020
2021
2022
2023
2024
2025
2026
2027
POSITION MANAGEMENT PROGRAM
GUIDELINES 20-7
General 20-7
Basic Position Management
Requirements 20-7
Organization Planning and.
Guidelines 20-11
Periodic Assessments 20-13
Reporting 20-14
Organization Nomenclature 20-14
Chart of levels of Organizational
Responsibilities 20-15
Span of Control 20-16
4/82
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MANAGEMENT OPERATIONS
DLMS 3
CHAPTER 2000 - POSITION MANAGEMENT AND ORGANIZATIONAL REVIEW
Paragraph
2030
2031
2032
2033
Content Page
USE OF DEPUTY, ASSISTANT, SPECIAL
ASSISTANT AND ASSISTANT TO
POSITIONS 20-18
Policy 20-18
Deputy and Full Assistant Positions 20-18
Special Assistants and Assistant to
Positions 20-19
2040
2041
2042
CLEARANCE OF MAJOR ORGANIZATION
AND POSITION CHANGES
Policy
Documentation
20-21
20-21
20-21
11
4/82
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SMfTHSONIAN INSTITUTION'S BUDGET PLANNING
-------
ATTACHMENT 1, page 1
SMITHSONIAN INSTITUTION
PLANNING AND BUDGET SCHEDULE FOR FY 1990 AND BEYOND
AND OTHER RELEVANT BUDGET MILESTONES
Activity Date
Priority Call issued to Bureaus/Offices; November 20, 1987
Bureaus/Offices initiate internal planning
meetings.
Members of Management Committee hold December 1-18
Group Planning/Priority meetings with (approximately)
their collective Bureaus/Offices to discuss
broad program directions and emphases.
Call to Bureaus/Offices for update to FY 1989 December 4 *
OMB narrative for Congressional submission.
Updated FY 1989 narrative for Congressional December 18 *
submission due to OPB.
FY 1989 Budget submission due to Congress. January 4, 1988 **
Bureaus/Offices submit responses to Priority January 5
Call to appropriate Management Committee
members with two copies to OPB; Management
Committee members begin individual meetings
with Bureau/Office directors on plans
and priorities.
1989-1993 Prospectus due to J. Hobbins January 15
for mailing to Board of Regents Executive
Committee.
Board of Regents Executive Committee meeting. January 21
* These dates will depend upon timing of the OMB passback and any
change to the January 4 date for Congressional submission
negotiated by OMB.
** It is possible OMB will negotiate a later submission date due to
delayed Congressional action on FY 1988 budget.
-------
ATTACHMENT 1, page 2
Board of Regents Meeting
1st Quarter Review of FY 1988 Budget
Management Committee/Bureau and Office
Planning/Priority Meetings completed.
Preliminary rates established for FY 1990 budget
call (rent, overhead, benefits, computer
charges, interest, audio visual, etc.)
Management Committee feedback to Bureaus
and Offices on Plans/Priorities completed.
OPB meets with Management Committee to review
revisions to Institutional Purpose and
Goals Statement and Secretary's "Areas of
Emphasis".
Spring Budget Call distributed to Auxiliary
Activities and Cost Centers.
Revised Institutional Purpose and Goals
statement and "Areas of Emphasis" prepared
by OPB and forwarded to the Secretary for
review and mark-up.
Congressional Hearings on FY 1989 Budget.
Institutional Purpose and Goals Statement,
Secretary's "Areas of Emphasis", and Soring
Budget Call distributed to Bureaus/Off ices.
Management Committee tentatively decides
amount of FY 1990 OMB request, and federal
and trust pools established.
Auxiliary Activities and Cost Centers submit
responses to the Spring Budget Call.
Board of Regents Executive Committee meeting.
Bureaus/Offices submit responses to the Spring
Budget Call.
February 1
February 3
February 17
March 1
March 7
March 9
March 11
March 15
March - April
(estimated)
March 25
April 13
April 15
April 21
April 22
2nd Quarter Review of FY 1988 Budget.
May 4
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ATTACHMENT 1, page 3
Board of Regents meeting; Institutional
Purpose and Goals Statement and "Areas of
Emphasis" discussed.
Spring internal Budget hearings held by
Management Committee members (federal and
trust); OPB advises Bureaus/Management
Committee members of technical adjustments
to submissions.
Assistant Secretaries share preliminary budget
recommendations with Bureaus/Offices & request
feedback.
Assistant Secretaries submit final federal and
trust budget recommendations and Five-Year
Prospectus projections to OPB and present them
to Management Committee.
Final update of FY 1990 Income Estimates from
Trust fund Auxiliary Activities.
Call to Bureaus/Offices to initiate preparation
of abstracts and program statements for OMB
Budget Submission.
OPB presents first Consensus Budget
recommendations to Management Committee.
Management Committee concludes deliberations
on federal and trust budgets and five-year
projections and notifies Bureaus/Offices of
final recommendations; Bureaus begin preparing
OMB justifications for approved increases, and
portions of Five Year Prospectus.
Inflation examples requested from selected
Bureaus/Offices.
OPB submits final recommended trust and federal
budgets to the Secretary.
Secretary approves federal and trust budgets;
Bureaus/Offices submit justifications for
approved increases and portions of Five-Year
Prospectus to OPB for submission to OMB and
Board of Regents.
Management Committee members and their staff
review and edit Bureau/Office budget narratives
for OMB submission.
May 9
May 9 - June 3
June 6
June 14-16
June 15
June 17
June 22
June 29
July 8
July 11
July 18
July 25 - August 12
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ATTACHMENT 1, PAGE 4
Inflation examples from selected Bureaus/
Offices due to OPB.
OPB begins assessment of FY 1988 year-end
federal and trust problems and opportunities.
Bureaus/Offices review final FY 1990
budget narrative for OMB submission, followed
by OPB assembly of final budget document.
3rd Quarter Review of FY 1988 Budget.
Assembly by OPB of a short summary of Five-Year
Prospectus for Regents' Executive Committee
begins.
FY 1990 budget submission to OMB, and Draft
Five-Year Prospectus due for mailing to Regents
for September meeting(s).
Board of Regents' Executive Committee meeting.
FY 1988 year-end funding determinations
made by Management Committee.
Board of Regents meeting.
FY 1988 ends, books close.
Cycle ends, Priority Call for FY 1991 and
beyond is distributed, and cycle begins again.
July 29
August 1
August 1-15
August 4
August 19
September 1
September 7
September 14
September 19
September 30
November 21
Prepared by:
Office of Programming and Budget
November 20, 1987
F001A 88.DOC
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SOURCES OF INFORMATION AND TRAINING
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ENVIRONMENTAL AUDITING:
SOURCES OF INFORMATION AND TRAINING
March 1988
Prepared for:
Regulatory Innovations Staff
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
401M Street, SW
Washington, D.C 20460
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PREFACE
This source guide to information and training on environmental
auditing was prepared by Policy Planning fc Evaluation, Inc.,
Vienna, Virginia, under contract No. 68-01-7252 for the
Regulatory Innovations Staff, Office of Policy, Planning and
Evaluation, U.S. Environmental Protection Agency.
This document was prepared for distribution to attendees at EPA's
March 1988 " Environmental Auditing Conference for Federal
Agencies". Any mention of organizations, products, or services
described in this document should not be construed to constitute
endorsement by EPA or Policy Planning & Evaluation, Inc.
Further, neither EPA nor PP&E guarantee the quality of the
products and services described in this document, nor that they
will necessarily continue to be offered by the respective
organizat ions.
All information on products, services, costs, etc. presented in
this document are accurate, to the best of the authors'
knowledge, as of March 1988. Any omission of environmental
auditing organizations, products, or services are inadvertent and
much regretted.
If you have comments on this document or wish to identify items
for inclusion in any potential revisions of this document, please
inform EPA's Regulatory Innovations Staff, PM-223, 401 M St.,
S.W., Washington, D.C. 20460.
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ENVIRONMENTAL AUDITING: SOURCES OF INFORMATION AND TRAINING
Table of Contents
General Introduction 1
A. Training: Courses 2
The Environmental Audit 3
Environmental Audits Course 5
Mastering Environmental, Health, and Safety
Auditing Techniques 7
Environmental, Health, and Safety Auditing:
New Direction/New Strategies 9
Environmental, Health, and Safety Auditing:
Advanced Skills and Techniques 11
Environmental Compliance Audits and Due Diligence.... 12
Environmental Auditing: Risk Management for
the Future 14
B. Training: Seminars and Presentations 15
Environmental Auditing Applications 16
Waste Minimization & Environmental Programs
Within DOD 17
C. Training: University Certificate Programs 18
Certificate Program in Environmental Auditing 19
D. Professional Organizations and Associations 21
Environmental Auditing Roundtable 22
Institute for Environmental Auditing 24
Environmental Auditing Forum 26
E. "Generic Auditing" 28
The Institute of Internal Auditors 29
International Loss Control Institute 31
F. EPA Sources of Information on Environmental Auditing 33
G. Periodicals 35
Environmental Auditor 36
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GENERAL INTRODUCTION
The purpose of this document is to provide a reference source for
persons interested in acquiring training in or information on
environmental auditing. The information in this document has
been categorized into six areas:
A. Training: Environmental auditing courses.
B. Training: Environmental auditing seminars and
presentations as part of larger conferences.
C. Training: University certificate programs in
environmental auditing.
D. Professional Environmental Auditing Organizations:
Organizations and associations devoted to environmental
auditing.
E. "Generic" Auditing: Sources of information and
training on general auditing skills and techniques
(usually focused on operations and financial auditing).
F. EPA Sources of Information on Environmental Auditing.
G. Periodicals: A publication devoted specifically to the
field of environmental auditing.
A more detailed description about each area is presented at the
beginning of the respective section.
The information for this document was obtained primarily from two
sources: brochures and other materials released by the various
organizations describing their products and services; and
interviews with appropriate persons in those organizations. More
information about organizations, products, or services may be
obtained by contacting each organization directly. Addresses are
provided.
Often we have borrowed phrases and terminology from the brochures
because we felt they best described the focus of the services
being offered. At the same time we have tried to be objective in
describing each program or organization.
Any comments on this document can be directed to the
Environmental Auditing Project, Regulatory Innovations Staff,
Mail code PM-223, U.S. Environmental Protection Agency. 401 M
Street, SW, Washington, D.C. 20460.
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A. TRAINING: COURSES
This section describes various programs, courses, seminars, etc.
offered by different organizations. Typically, each training
program runs from between one to four days, has a fixed
scheduled, and is open to the public. In addition, many of the
organizations offer in-house training programs at company or
agency facilities. Costs for hotel accommodation or related
expenses are not included in the registration fees.
Each program description in this section contains essentially the
same type of information:
• Title of program, course, or seminar
• Source (organization) offering the training, with the
address
• Profile of the training program
• Topics covered
• Schedule
• Faculty, and
• Cost.
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Training
Title: The Environmental Audit
Source: Federal Publications, Inc.
1120 20th St., N.W.
Washington, D.C. 20036
Profile
The course is a program of training in methods of planning,
conducting, and using an environmental audit. Its purpose is to
provide assistance to those involved in the process of designing
and incorporating an audit system into the activities of their
respective organizations. The course includes lectures and
question-answer sessions. Course participants receive a copy of
the book All About Environmental Auditing. by Ridgway M. Hall,
Jr. and David R. Case, who are members of the course faculty.
Topics Covered
The course is divided into five main areas:
• "Reasons for an audit" discusses the role of audits as
management tools to ensure cost-effective compliance; and
the use of audits to prevent violations, even during periods
of growth and expansion of the organization.
• "Planning the audit" discusses the criteria for selecting
the members of the audit team, the scope of review and
subjects to cover (such as regulatory requirements,
maintenance procedures, and monitoring systems), and
financial considerations.
• "Regulatory requirements" presents an overview of
environmental controls, such as various federal, state, and
local laws, permits, and compliance schedules; and outlines
the implications of these controls on on-site compliance
obligations for air emissions, water discharges, etc.
• "Conducting the audit" describes the process of obtaining
information through the use of documents, questionnaires,
interviews, and site visits; discusses aspects of
confidentiality and how to protect it; and provides an audit
checklist, highlights points of pollution discharge to
inspect; and reviews aspects of maintenance procedures.
• "Using the audit" presents a systematic process of analyzing
the results (including organizing the information and
determining compliance); applying the results to determine,
among other things, how costs may be reduced, and ways to
limit potential liability; and coordinating compliance.
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Training
Schedule
The course is for two days and was last held in San Francisco on
November 16-17, 1987, and in Washington, D.C. on October 15-16,
1987. No information is currently available on future courses.
Core Faculty
Ridgway M. Ball, Jr. is a partner in the Washington, D.C. law
firm of Crowell & Moring.
David R. Case is an attorney in private practice, and is the
General Counsel of the Hazardous Waste Treatment Council, a
national trade organization.
Additional Faculty
The core faculty is supplemented by speakers with expertise in
hazardous waste management regulation, and in the engineering and
policy analysis aspects of industrial chemical waste management.
Cost
The registration fee is $675. Course registrants receive a
complimentary copy of the course text All About Environmental
Auditing.
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Training
Title: Environmental Audits Course: Protecting Your Company
and Yourself
Source: Governnent Institutes Inc.
966 Hungerford Drive, #24
Rockville, MD 20850
Profile
The purpose of the course is to teach managers and engineers how
to audit their facilities for environmental compliance and
protect themselves from liabilities. The course includes
lectures and question-answer sessions. Course participants
receive a copy of the book Environmental Audits, edited by
Lawrence B. Cahill and Raymond W. Kane, who are also members of
the course faculty.
Topics Covered
• "Current Federal & State Agency Activities in Environmental
Auditing" presents auditing from a regulator's perspective;
describes EPA's current policy on auditing; and reports on
State activities in environmental auditing.
• "Legal Issues You Should Address Before and After the Audit"
discusses the potential civil and criminal liabilities of
the auditing company and the auditors; outlines current
enforcement strategies and compliance issues; and addresses
the problem of formulating a corporate policy on reporting
violations.
• "Conducting the Audit—What Questions You Should Ask; What
You Should Look For" reviews specific, common problems and
compliance issues typically found during audits; uses case
studies to point out problems.
• "Description and Comparison of Existing Industrial Audit
Programs" surveys a variety of industrial programs; outlines
both the differences and similarities in management
approaches, policies, and procedures; and reviews complete
software available for recordkeeping and reporting
requirements.
• "Special Purpose Audits" defines the special audit needs and
techniques for RCRA insurance; risk assessments; property
sales and transfers; underground storage tanks; and off-site
hazardous waste disposal vendors.
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Training
Schedule
The course is for two days and was last held in Washington, D.C.
on March 8-9, 1988. The next course is tentatively scheduled for
July 27-29, 1988 in Hilton Head, SC, and the subsequent one for
October 20-21, 1988 in Washington, D.C.
Core Faculty
Lawrence Cahill is vice president of HART Environmental
Management Corporation, an environmental Management consulting
firm.
Raymond Kane is also a vice president at HART.
Additional Faculty
The course also generally includes presentations by a lawyer, an
EPA representative, and one or more corporate environmental
managers.
Cost
The registration fee for the course is $795, which includes a
copy of the course text Environmental Audits.
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Training
Title: Mastering Environmental, Health, and Safety Auditing
Techniques
Source: Arthur D. Little, Inc.
Center For Environmental Assurance
15 Acorn Park
Cambridge, MA 02140
Profile
The course is designed to train environmental, health, and safety
(EHS) auditors in state-of-the-art auditing techniques and
methodologies. This is an intensive, skills-oriented training
course focusing on the practical aspects of conducting audits.
The course is designed specifically for EHS professionals serving
as audit team members, as well as for managers and attorneys.
Course participants are provided with audit protocols,
presentation summaries, and monographs on specific audit
techniques. The course includes lectures and case studies.
Topics Covered
The course has four sections—reviewing the basics; understanding
internal controls; gathering audit evidence; and reporting and
critiquing the audit. Discussions include topics such as:
• "Overview of the Audit Process" presents the five
fundamental audit steps: understanding management systems,
assessing internal controls, gathering audit evidence,
evaluating audit findings, and reporting exceptions.
• "Protocols and Questionnaires" provides participants the
opportunity to develop plans for an EHS auditing case study.
• "Assessing Internal Controls" allows participants to review
sample working papers to identify critical control points in
facility EHS management systems.
• "Data-Gathering Techniques" puts participants in the roles
of actual audit team members, and allows them to interact
with key facility personnel to obtain information relevant
to the completion of the case study-
• "Preparing the Audit Close-Out" is a session for audit teams
to review and evaluate evidence gathered during the audit,
and to develop a list of exceptions to present to facility
management at the mock close-out meeting.
• "Difficult Audit Situations" discusses audit problems,
alternatives for resolving conflicts, and reporting critical
findings.
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Training
Schedule
The course is for four days and is offered 4-6 times per year.
During 1988, courses are currently scheduled for Apri/ 26-29,
July 12-15, September 13-16, and November 1-4.
Faculty
The course is conducted by members of the Arthur D. Little
consulting staff.
Cost
The cost of the four-day course is $795, which includes a
complete set of course materials.
8
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Training
Title:
Source:
Environmental, Health,
Direction/New Strategies
and Safety Auditing:
New
Arthur D. Little, Inc.
Center For Environmental Assurance
15 Acorn Park
Canbridge, MA 02140
Profile
This seminar is designed to provide environmental, health, and
safety (EHS) professionals (including audit program managers,
auditors, attorneys, and other interested parties) with the tools
to critically evaluate and update their organization's EHS audit
program or plans. Participants are provided with audit
protocols, presentation summaries, and related material. The
course consists primarily of lectures.
Topics Covered
• "Context for New EHS Auditing Directions" - discusses the
changing focus of EHS audits, and ways to meet the needs of
top management through an audit program.
"Methods for Enhancing Audit Program Effectiveness"
describes ways to create audit program independence within
the organization; ways to balance key audit program elements
to ensure program effectiveness; and characteristics of
leading audit programs.
"Strategies for Increasing the Quality of EHS Audit Field
Work" focuses on mastering basic audit skills; developing
effective internal procedures and standards; and
understanding key principles and techniques for writing
audit reports.
• "Emerging Issues in EHS Auditing" introduces issues such as
auditing overseas locations, auditor certification and
liability, and special purpose audits.
• "Future Trends in EHS Auditing" discusses what auditing may
be like in the 1990's, and the changing focus to management
system audits.
Schedule
The seminar, called an "executive briefing", is for one day, and
is held 4-6 times per year at locations across the United States
and Canada. It was last held on December 10, 1987 and the next
course is scheduled for April 14, 1988 in Cambridge, MA.
9
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Training
Faculty
The course is conducted by »e»bers of the Arthur D. Little
consulting staff.
Cost
The registration fee is $495, which includes all program
•aterials.
10
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Training
Title: Environmental, Health, and Safety Auditing: Advanced
Skills and Techniques
Source: Arthur D. Little, Inc.
Center for Environmental Assurance
15 Acorn Park
Cambridge, MA 02140
Profile
This course is specifically designed for environmental, health,
and safety auditors who have either attended Arthur D. Little's
four-day basic audit skills and techniques course, or have at
least two years' experience as full-time auditors. This advanced
training program is an interactive course that focuses on
enhancing auditors skills and techniques, and allows auditors to
refine their auditing approach. Course participants are provided
with a training manual, presentation summaries, and monographs on
specific audit techniques. The course includes lectures, small
group discussions, role playing, and other exercises.
Topics Covered
This course is divided into five sections—refining interviewing
skills, developing working papers, selecting samples, formulating
accurate findings, and enhancing team leadership skills.
Schedule
The two-day course is next scheduled for June 14-15, 1988 in
Cambridge, MA.
Faculty
The course is conducted by senior members of Arthur D. Little's
consulting staff, and by several industrial auditing
professionals.
Cost
The cost of the course is $595, which includes a complete set of
course materials.
11
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Training
Title: Environmental Compliance Audits and Due Diligence
Source: Center for Professional Advancement
P.O. Box H
East Brunswick, NJ 08816
Profile
The course is designed to provide a working knowledge of the
environmental audit process. There is special emphasis on the
implications for real estate and other business transactions,
permitting, and selection of waste management facilities. It
focuses on practical information on design of the audit,
organizational approaches to facilitate the audit, and data
acquisition and evaluation. The course is intended for a wide
range of participants including engineers, scientists, attorneys,
and environmental managers. It consists primarily of lectures.
Topics Covered
• "Resource Conservation and Recovery Act" discusses issues
pertaining to permitting and compliance, hazardous waste
handling and storage, documentation and record keeping,
evaluating haulers, and audits of off-site facilities.
• "Water and Air" focuses on NPDES and air permitting
requirements, and includes a discussion on recent
developments in toxics regulation.
• "Superfund" covers hazardous substance releases,
investigations, remedial options, SARA, risk assessment,
cost estimates, and using audits as a tool to identify and
minimize risks.
• "Real Estate and Business Transactions—Due Diligence and
Allocating the Risks" presents the concept of due diligence
from both the seller's and the buyer's perspective. It also
discusses how to allocate risks, and SEC disclosure issues.
• "Compliance Audits—Practical Guides" outlines: EPA
guidelines for audits; roles of a company's management and
staff in an audit; interview and questionnaire responses;
and confidentiality and privilege issues.
Schedule
The course is for three days and was last held in East Brunswick,
NJ, on September 14-16, 1987. The next course has not been
12
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Training
scheduled yet, but is expected to be scheduled for September 1988
at the sane location. The course curriculum and faculty members
are also expected to be the sane.
Core Faculty
Dr- James H. Clarke is President of AWARE Inc. in Nashville, TN
Bryant C. Danner is a partner in the law firm of Latham fc
Watkins, which has offices in several cities, including
Washington, D.C.
Additional Faculty
The course also includes presentations by other lawyers and
environmental managers.
Cost
The course registration fee is $830, which includes course notes.
13
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Training
Title: Environmental Auditing: Risk Management for the Future
Source: University of Wisconsin—Madison
Department of Engineering Professional Development
432 North Lake Street
Madison, WI 53706
Profile
The course is designed for environmental managers, attorneys and
consultants who deal with environmental risks, regulators, and
insurance professionals. No prior auditing experience is
necessary. The course is a joint effort between the University
of Wisconsin—Madison and the Institute for Environmental
Auditing (described in this document's section on professional
organizations).
Topics Covered
• Guidelines for developing an environmental auditing program
• Using auditing checklists
• Liability and legal responsibilities of auditing
• Conducting specialty audits for underground storage tanks,
waste minimization, and environmental impairment liability
insurance
Schedule
The course is for two days and is planned for June 7-8, 1988 at
the University of Wisconsin, Madison.
Faculty
Courses are taught by the following guest speakers:
Frank Priznar, Booz, Allen & Hamilton, Bethesda, MD.
Bill Gulledge, Environmental Insurance Management, McLean,
VA.
John Palmisano, AERtX Division, RMT Inc., Washington, D.C.
John Laumer, National Safety Council, Chicago, IL.
Mary Morningstar, Jellinek, Schwartz, & Connoly, Washington,
D.C.
• Victor Young, ARCO, Los Angeles, CA.
Cost
The registration fee is $485.
14
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B. TRAINING: SEMINARS AND PRESENTATIONS
The courses described in the previous section are offered
exclusively as training packages in environmental auditing. In
contrast, the programs described in this section are presented in
conjunction with, or as part of, a larger conference in a related
professional field. In addition, every year professional and
environmental organizations sponsor conferences where the primary
focus is not environmental auditing, but which sometimes include
a session on auditing. Examples of such organizations and their
addresses are:
1. Water Pollution Control Federation
601 Wythe Street
Alexandria, VA 22314-1994
2. Air Pollution Control Association
Box 2861
Pittsburgh, PA 15230-2861
3. American Institute of Chemical Engineers
345 East 47th Street
New York, NY 10017
4. Hazardous Waste Treatment Council
1440 New York Avenue, N.W., Suite 310
Washington, D.C. 20005
5. HAZTECH International
13555 Bel-Red Road
C-96870
Bellevue, WA 98009
6. HazMat Central
c/o Tower Confer«>ice Management Co.
800 Roosevelt Ru-d, Bldg. E—Suite 408
Glen Ellyn, IL 60137-5835
7. National Association of Environmental Professionals
P.O. Box 9400
Washington, D.C. 20016
15
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Training
Title: Environmental Auditing Applications
Source: HAZMACON 88
c/o Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Profile
"Environmental Auditing Applications" is one of the training
seminars being presented at HAZMACON 88. HAZMACON is a
conference and exposition on hazardous materials management that
features lectures, exhibits and training seminars, and is
sponsored by the Association of Bay Area Governments.
The seminar, which is presented by the University of California
at Irvine, reviews and demonstrates the principles of
environmental auditing and examines emerging areas where auditing
may be valuable. The seminar also involves a practical exercise
in devising an auditing strategy for a specific case. Results of
the case study are presented and evaluated by student teams.
The seminar has applications ranging from evaluating the safety
of real estate transactions of industrial property to
establishing risk, hazards, and liabilities of using hazardous
materials in manufacturing.
Schedule
Although HAZMACON is for three days, the seminar on environmental
auditing is for one day only. Hazmacon is to be held in Anaheim,
CA on April 5-7, 1988, and the seminar, along with other training
workshops, is to be held a day earlier on April 4.
Faculty
Dr. R. Nichols Hazelwood is the Director of Environmental
Programs, IT Corp., Irvine, CA.
Vinay Dighe is with Occidental Petroleum Corp., Los Angeles, CA.
Cost
The fee for the seminar is $115.
16
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Training
Title: Waste Minimization & Environmental Programs within DOD
Source: American Defense Preparedness Association
Rosslyn Center, Suite 900
1700 N. Moore Street
Arlington, VA 22209-1942
Profile
The symposium deals with hazardous waste minimization issues and
the implementation of environmental programs at Department of
Defense installations. It focuses on the concerns and problems
faced by DOD installations in anticipating and complying with
regulatory requirements. The symposium is intended as a forum
for the government and the private sector to share ideas, to
exchange information on operations, and to share solutions to
common concerns.
The symposium is meant for persons from government and industry,
from both professional and technical fields. Such fields include
funding, planning, identifying, and designing environmental
programs; and handling, storing, transporting, and minimizing
materials that present environmental hazards.
Topics Covered
Among the topics discussed are environmental audits for the
Army's industrial base, Army, Navy, Air Force and Defense
Logistics Agency environmental programs, waste minimization
initiatives, and water quality assessments of DOD installations.
Schedule
The symposium is for three days and was last held on April 28-30,
1987 in Long Beach, California. The next symposium is
tentatively cheduled for October 19-21, 1988 in New Orleans,
Louisiana. The topics are expected to be the same.
Faculty
The faculty is comprised of guest speakers from various agencies
and organizations, including the EPA, the Navy, the Army, the
U.S. Congress Office of Technology Assessment, and a number of
private consulting firms.
Cost
The registration fee for the 1987 symposium was $235 for ADPA
members, and $255 for non-members (this includes membership to
ADPA). The fee for members of the U.S. Government and academia
was $125. No information is available on the fee for 1988.
17
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C. TRAINING: UNIVERSITY CERTIFICATE PROGRAMS
One training program in environmental auditing is currently
offered for academic credit. That program is described in this
section. The program is structured differently from the other
programs described in the earlier sections. It has courses of
longer duration, each offered in sessions that coincide with the
university academic quarters. Furthermore, the program leads to
a certificate of proficiency in environmental auditing.
18
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Training
Title: Certificate Program in Environmental Auditing
Source: University of California, Irvine
University Extension
P.O. Box AZ
Irvine, California 92716
Profile
The program is designed to expand the knowledge and management
skills of environmental professionals in environmental auditing.
The program provides both theoretical and practical information,
and is oriented towards imparting to program participants the
skills necessary to perform environmental audits.
The- program is run like other university academic programs: the
curriculum is spread over several months, with each course within
the program normally being offered during a different quarter of
the school year, and each participant is graded at the course
conclusion.
Each of the four courses in environmental auditing is for 30
hours and contributes to 3 units of credit. In addition, because
the Certificate Program in Environmental Auditing builds on
courses already established in the closely
Program in Hazardous Materials Management,
latter program are prerequisites for
environmental auditing program.
related Certificate
two courses from the
enrollment in the
Persons interested in the program may opt either to complete the
180 course hours (six 3-unit courses) required for the
certificate, or simply to take one or more courses without
completing the requirements for the certificate.
Sample Topics
"Introduction to Environmental Auditing" deals with the
basic theories of environmental auditing. The audit process
is described, methods for defining environmental audit goals
and boundaries are developed, and techniques are presented.
"Audit Skills and Techniques" covers methods for planning,
conducting, evaluating, and reporting on environmental
audits. Includes case examples and structured role-playing,
and discussions on topics such as modifying protocols, data
gathering techniques, interviewing, and reporting findings.
"Audit Systems Design and Tools" presents criteria for
environmental auditing systems design, and discusses how
19
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Training
auditing tools are developed for specific situations. This
is done through case studies, with audit examples being
chosen from industrial, business, and government operations.
"Seminar in Environmental Auditing" presents specific,
unique examples of actual audits, and examines the basic
environmental principles that underlie environmental
compliance efforts. The objective is to develop and define
auditable standards by which environmental compliance
management can be assessed.
Schedule
Each course is for about five weeks, with sessions once a week
for six hours each, totalling 30 hours. The last course to be
held was "Introduction to Environmental Auditing" (February 22
through March 28, five Mondays, 2-5 p.m. and 6:30-9:30), and
classes were held in Fountain Valley, near Irvine. The schedule
for future courses is not currently available..
Core Faculty
R. Nichols Hazelwood, Director of Environmental. Programs, IT
Corporation, teaches "Introduction to Environmental Auditing".
The names of instructors for the other courses are not currently
available.
Cost
The registration fee for each course is $250. In addition,
candidates must pay a nonrefundable fee of $25 with an
Application for Candidacy upon entering the program. The
registration fee does not include the cost of the text
Environmental Auditing: Fundamentals and Techniques. by J. Ladd
Greeno, Gilbert S. Hedstrom, and Maryanne DiBerto, which is $60.
20
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D. PROFESSIONAL ORGANIZATIONS AND ASSOCIATIONS
This section describes three organizations dedicated solely to
the practice and professional development of environmental
auditing.
The organizations are primarily forums for the dissemination of
information on environmental auditing, and present opportunities
for members to interact with professionals in t^vernment,
industry, law, etc. Membership to any of the organizations is
open to all interested professionals.
The type of information presented for each organization in this
section is essentially the same:
• Name and address of the organization
• A description of the organization's activities, such as
meetings, conferences, and training programs
• Publications
• Profile of participants
• Organizational structure, and
• Membership and other costs.
21
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Prof 1 Organizations
Organization: Environmental Auditing Roundtable
Address: P.O. Box 23798
L'Enfant Plaza Station
Washington, D.C. 20026-3798
Background
The Environnental Auditing Roundtable (EAR) is an organization
dedicated to furthering the development and professional practice
of environmental auditing. It serves primarily as a forum for
sharing information. It was founded in 1982 by several managers
of corporate environmental audit programs.
Activities
• Quarterly meetings: EAR members conduct two-day meetings
every quarter, generally in the Washington, D.C. area.
Meeting agendas typically include a description of a
corporate audit program; formal presentations on various
auditing topics; group exercises; and informal discussions.
• Work groups: EAR members engage in informal sessions to
exchange information and facilitate in-depth discussions on
topics such as audit system design, audit procedures,
auditor qualifications, international audits, legal issues,
and computer applications.
• Committees: Members can volunteer for standing committees
on EAR programs, communications, nominations, finance,
training and education, and membership; or ad hoc committees
addressing specific issues of interest to members.
Sample Agenda Topics
Recent EAR meetings have included presentations, discussions, and
written material on: environmental auditing programs and
practices; regulatory agency policies; requirements for audits in
enforcement actions; auditing community right-to-know
requirements under SARA Title III; federal agency audit programs;
internal reporting of audit findings; auditor education, auditor
certification, and audits for real estate transactions.
Publications
• Publications on environmental auditing programs, practices,
and issues are frequently available at EAR meetings or from
EAR participants and speakers.
• Highlights of each meeting are sent to members.
22
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Prof 1 Organizations
Profile of Participants
Most EAR Bembers are practicing environmental, health, and safety
auditors with extensive field experience. However, membership is
open to anyone with a professional interest in the practice of
environmental auditing. Members represent a wide variety of
professional disciplines and organizations, including industry,
consulting firms, government agencies, and law firms.
Organizational Structure
Membership in the Roundtable is open to all environmental
auditors and other interested professionals. The officers of the
organization are the five Directors, elected pursuant to the
EAR's by-laws to constitute the Board of Directors. The Board
establishes administrative policies, and among its members are
the Chairperson and Treasurer- The Board allocates the duties
and responsibilities to perform the administrative functions of
the organization. These functions are performed by several
committees that have been established as a permanent part of the
organization. Members are governed by by-laws and a code of
ethics.
Membership and Other Fees
Members pay an initiation fee of $35 to join the Roundtable. In
addition, members wishing to attend the quarterly meetings pay a
fee usually of $35 per meeting to cover luncheon costs, meeting
room and audio-visual equipment rentals, etc.
23
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Prof 1 Organisations
Organization: Institute for Environmental Auditing
Address: P.O. Box 23686, L'Enfant Plaza
Washington, D.C. 20026-3686
Background
The Institute for Environmental Auditing (IEA) is an organization
dedicated to the enhancement of the environmental auditing
profession. Its goals are to provide a forum for education for
auditors, and to establish the professional status of those
engaged in the field. The IEA was chartered in 1987.
Activities
• Meetings: The IEA has active chapters in several states in
the U.S., which conduct periodic meetings.
• Training: The IEA is in the process of developing a
training program in environmental auditing fundamentals.
With the Air Pollution Control Association the IEA will
present one-day training sessions in several locations. A
second, more extensive two-day course is also being
developed in association with the University of Wisconsin's
Department of Engineering Professional Development.
• Other: Members of IEA contribute to State regulatory
initiatives and present position papers on environmental
audi ting.
Publications
The IEA publishes a quarterly newsletter called "Working Papers"
for its members. It includes environmental auditing articles and
news, and information on training programs, employment
opportunities, and publications related to environmental
auditing.
Profile of Participants
Membership is open to all interested professionals. These
include professionals from the fields of consulting, engineering,
law, and finance, as well as from regulatory agencies.
Organizational Structure
The IEA is a non-profit organization incorporated in Washington,
D.C., whose membership is open to all interested professionals.
24
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Prof 1 Organization*
The organization consists of a board of directors, an executive
director, an administrative committee,(responsible for finances,
membership, correspondence, and business), and an activities
committee (responsible for newsletters, local chapter support,
training, and conferences). Th.e IBA has five chapters—the Rocky
Mountain, Pacific Northwest, New York State, Atlanta, and Mid-
Atlantic chapters.
Membership and Other Fees
Members pay an annual fee of $50, which entitles members to the
newsletter, to attend meetings, and discounts on any future
publications. Fees for seminars vary according to the type of
seminar being sponsored.
25
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Prof 1 Organizations
Organization: Environmental Auditing Forum
Address:
c/o Mr. Vinay Dighe
Occidental Petroleun
10889 Wilshire Blvd., Suite 1160
Los Angeles, CA 90024
Background
The two goals of the Environmental Auditing Forun (EAF) are to
provide opportunities for the exchange of ideas and information
about environmental auditing concepts, principles, and practices;
and to facilitate development of improved environmental auditing
and protection programs. EAF was founded in 1986 to better serve
the needs of interested persons in California.
Activities
Meetings:
California;
and group
three main
The EAF generally meets quarterly, usually in
and meetings typically consist of presentations
discussions. A meeting agenda usually covers
areas:
A discussion of an actual audit program implemented by
a company.
A discussion of enforcement issues at the federal and
state level, initiated by a member from the government.
An update on
field of
California.
legislative activities that may affect the
environmental auditing, especially in
Publications
Meeeting attendees receive minutes of the EAF meetings.
Profile of Participants
EAF meeting attendees represent industry,
government, consulting, insurance, and banking.
construction,
Organizational Structure
The EAF is governed by a five-member steering committee. In
addition, there is an informal advisory committee that drafts
issues for the steering committee to develop policy positions.
26
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Prof 1 Organizations
Membership and Other Fees:
Individuals are required to pay a fee of $10 per year to be
included on the Bailing list for information on activities.
Registration fee for meetings is $30, which covers the cost of a
luncheon, equipment and room rental, etc.
27
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E. "GENERIC" AUDITING
This section presents information on organizations and training
programs for auditing other than environmental auditing. Because
the principles of auditing, whether financial auditing,
operations auditing, or environmental auditing, are basically the
same, this section nay help the reader to put environmental
auditing in perspective with other types of auditing. Also, some
skills learned from one type of audit training are often
applicable to other types of audits.
Although only two organizations have been described in this
section, information on training programs for "generic" auditing
skills and techniques may be available from various Federal audit
agencies. These training programs will probably focus on
financial or operations auditing, and may be available only to
employees of the same agency- Examples of such agencies, and
their addresses are:
• Air Force Audit Agency
Headquarters
AFAA/DA, Building 528
Norton Air Force Base, CA 92409-6001
• Army Audit Agency
HQDA (SAAG-PRP)
3101 Park Center Drive
Alexandria, VA 22302-1596
• General Accounting Office
Training Center, Room 7424
441 G St., N.W-
Washington, D.C. 20548
28
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'Generic" Auditing
Organization: The Institute of Internal Auditors
Address: 249 Maitland Aye., P.O. Box 1119
Altaaont Springs, FL 32701
Background
The Institute of Internal Auditors (IIA) is an international
professional organization to promote the dissemination of
knowledge in the area of internal (primarily financial) auditing.
It consists of more than 30,000 members in 102 countries, with
180 chapters and affiliates worldwide. It was founded in 1941 in
New York.
Educational Programs
• Three to five day seminars range from basics, such as
techniques for the beginning financial or operations
auditor, to specialized subjects such as internal auditing
for the oil and gas industry.
• Special interest conferences address topics that have
broader impact on the profession of internal auditing.
Recent conferences have focused on telecommunications,
fraud, contract and construction auditing, internal auditing
in government, and relevant legislation. No courses are
offered specifically on environmental auditing.
• IAA Media-Assisted Training Programs include video-assisted
seminars, audio cassettes, self-study programs, and in-house
training.
Conferences
Annual international and regional conferences give members
opportunities to meet and share perspectives with people in
disciplines such as government, industry, construction, and
finance.
Certified Internal Auditor Program
The program is designed to enhance recognition of internal
auditing and provide the proper direction to internal auditors
who seek to further their professional development and
advancement. Members are certified after being tested, and
certification is considered a mark of professional achievement
and commitment.
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'Generic" Auditing
Publications
• The IIA publishes a journal, "Internal Auditor", which has
up-to-date information on auditing practices and techniques.
• A newsletter, "IIA Today", provides news on internal
auditing and highlights chapter activities.
• A Banual, "Professional Internal Auditing Standards Volume",
defines the criteria by which the operators of an internal
auditing department are to be evaluated.
• A software package, "auditMASTERPLAN" incorporstes the IIA's
"Standards" (as defined in the manual), and IL based on the
book "Planning for the Internal Audit Function".
In addition, various publications on internal auditing, which are
not published by the IIA, are also available for sale to neuters.
Cost
Membership costs vary for management level and for staff level
•embers. Managers pay annual dues of $110 plus a one-time
application fee of $15; staff members pay annual dues of $60 plus
the $15 application fee. These fees includes subscriptions to
the bi-monthly journal "Environmental Auditor'r and to the
newsletter "IIA Today"; and entitles the member to reduced rates
for seminars, conferences, and publications. Costs of seminars
and conferences vary from $545 to $845 for members and $595 to
$895 for nonmembers.
30
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'Generic" Auditing
Organization: International Loss Control Institute
Address: Highway 78
P.O. Box 345
Loganville, 6A 30249
Background
The International Loss Control Institute is an organization whose
primary function is to offer courses related to safety and loss
control. These are designed to help a company or agency improve
their efficiency, protect their resources, and reduce their
costs. In addition, the ILCI offers on-site training, auditing
and consulting services, training packages, and books, films, and
videotapes on a variety of related subjects.
Courses
The ILCI offers eight courses on subjects such as safety
•anagenent, loss control management, and resource aanagement. Of
particular interest are two courses for safety auditors:
• "Accredited Safety Auditors Course" presents Bethods and
techniques of safety program Banageaent auditing, including
interviews, examination of records, and inspections; reviews
critical terminology and program requirements to assure
consistency within the International Safety Rating System;
and defines the activities involved in managing a safety and
health program.
• "Accredited Safety Auditors Review Course" is designed to
update Accredited Safety Auditors' knowledge and skills
related to the International Safety Rating System; and to
provide practical tools that can aid auditors in
implementing effective loss control programs in their
respective organizations.
Schedule
The duration of the eight courses varies froB two to five days.
The first auditors course is for five days and the auditors
review course is for three days. Most of the courses, including
the two on auditing, are offered several times a year and at
different locations.
Cost
The registration fee is different for each course, and varies
froB $342 to $750 for ILCI members, and $380 to $950 for non-
members .
31
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'Generic" Auditing
Other Services
The ILCI can tailor their courses to the specific needs of
an organization.
The ILCI's Membership Program allows organizations to
benefit from the International Safety Rating System,
particularly in terns of establishing health and safety
standards, Measuring and evaluating the effectiveness of the
health and safety program, and correcting deficiencies.
The ILCI's auditing and consulting services include
comprehensive evaluations of the effectiveness of health and
safety programs, and identification of program activities
contributing to safety and loss control.
The ILCI offers reference manuals, computer software for
management, books, training packages, reports, periodicals,
films, and videotapes.
32
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F. BPA SOURCES OF INFORMATION ON ENVIRONMENTAL AUDITING
Information on environmental auditing is available from several
offices in the EPA as well' as from a number of documents
published by the EPA. Three BPA offices, with their Bail codes
and telephone numbers, are listed below. All are located at 401
M Street, S.W., Washington, D.C. 20460.
1. Office of Federal Activities, A-104
Federal Facilities Compliance Staff (202) 382-3270
2. Office of Enforcement and Compliance Monitoring, LB-133
Compliance Policy Planning Branch (202) 382-7550
3. Office of Policy, Planning and Evaluation, PM-223
Regulatory Innovations Staff (202) 382-2726
Publications available from the EPA under various categories are:
A. Policy and Guidance
1. "Environmental Auditing Policy Statement", Federal
Register Vol. 51, No. 131, Wednesday, July 9, 1986, pp.
25004-25010.
2. "Final EPA Policy on the Inclusion of Environmental
Auditing Provisions in Enforcement Settlements",
November 1986.
B. Bibliographies
1. Annotated Bibliography on Environmental Auditing. March
1988.
C. Protocols
1. Environmental Audit Protocol for EPA Facilities.
November 1986.
2. Multi-Media Compliance Audit Procedures. June 1987.
D. Reports and Case Studies
1. "Study of the Benefits of Environmental Auditing
Provisions in Enforcement Settlements", March 1988.
2. "Current Practices in Environmental Auditing", February
1984.
3. "Duties to Report or Disclosure Information on the
33
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EPA Sources
Environmental Aspects of Business Activities",
September 1985.
4. "Benefits of Environmental Auditing: Case Examples",
December 1984.
In addition, the Office of Federal Activities is planning to
publish materials on environmental protocols and guidelines on
environmental auditing program design for Federal agencies.
These materials may be available late in 1988.
34
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6. PERIODICALS
Articles on environmental auditing regularly appear in
professional journals, Magazines, and other periodicals. In
addition, one journal is devoted to the applied practice of
environmental auditing. That journal is discussed in this
section.
35
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Periodicals
Name: Environmental Auditor
Source: Springer International
Springer-Verlag New York, Inc.
175 Fifth Avenue
New York, NY 10010
Objectives
The journal is dedicated to serving all professionals interested
in environmental auditing. Its goals are to encourage the use of
environmental auditing as a Beans of achieving and maintaining
compliance with environmental requirements; to evaluate the
effectiveness of environmental management systems; to assess
risks; and to identify and correct environmental hazards.
The journal's thesis is that through environmental auditing,
businesses can anticipate pollution control problems and related
environmental concerns, rather than being forced to react to
crises as they occur. A typical issue will examine legal,
scientific, and economic problems and solutions, and raise
environmental issues for further analysis.
Frequency
The first issue is expected to appear in May 1988. Four issues
per year are planned. Persons interested in subscribing to the
journal can get more information from the address above.
Contributions
Persons interested in contributing manuscripts to the journal may
contact the editors at:
ENVIRONMENTAL AUDITOR
P.O. Box 3818
Hartford, CT 06103
(203) 528-9677
Cost
The cost of subscription is $168.50 per year-
36
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ANNOTATED BIBLIOGRAPHY ON ENVIRONMENTAL
AUDITING
-------
ANNOTATED BIBLIOGRAPHY
ON
ENVIRONMENTAL AUDITING
March 1988
Seventh Edition
Prepared for:
Regulatory Innovations Staff
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
-------
The seventh edition of the bibliography on environmental auditing was
prepared by Policy, Planning, & Evaluation, Inc., Vienna, Virginia, under
contract No. 68-01-7252 for the Regulatory Innovations Staff, Office of Policy,
Planning and Evaluation, U.S. Environmental Protection Agency.
-------
ANNOTATED BIBLIOGRAPHY ON ENVIRONMENTAL AUDITING
This bibliography is neant to be a reference for individuals interested in
environmental auditing, i.e., internal management systems for reviewing facility
operations and practices to assess and verify compliance with environmental
regulations and corporate policies. Environmental auditing, as an internal
management tool, offers significant potential benefits for the environment, for
industryt and for state and Federal agencies. It can better promote reduction in
emissions, effluents, and solid wastes; assure corporate management that its
facilities are in compliance with environmental requirements; and identify areas
of potential cost savings while reducing strains on governmental enforcement
programs. EPA has endorsed the concept of environmental auditing and is
commtitted to encouraging its expanded use.
This bibliography categorizes entries by subject area, based on each
publication's major area of emphasis. Many publications cover several subject
areas, but each publication is listed only once in this bibliography. The
subject areas are:
A. General Literature on Environmental Auditing
B. Audit System Design and Methodology
C. Confidentiality, Disclosure, and Other Legal Issues
D. Industry Experience and Perspectives
E. Environmental Impairment Liability, Risk Assessment, & Property Transfer
F. Federal, State, and Local Perspectives and Activities
Each entry includes the author and type of document as well as a brief
abstract which summarizes the subject areas covered. The annotation should allow
the reader to determine whether a publication covers subjects other than the one
under which the publication is categorized in this bibliography. In addition,
each entry provides the source from which the reader may obtain the document.
Some of the materials listed may be obtained at no cost; however, others may have
to be purchased from the source listed or obtained from a library.
This bibliography does not exhaust the list of all of the published
articles, papers, and reports on environmental auditing. Rather, it includes
those publications providing unique perspectives and facts on environmental
auditing or which seem of greatest potential use to organizations establishing
auditing programs. Any comments or questions regarding this bibliography can be
directed to the Environmental Auditing Project, Regulatory Innovations Staff (PM-
223), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC
20460 or (202) 382-2726.
Note; The materials included in this bibliography have not been endorsed by EPA
or any other government entity. Any views or interpretations contained in these
referenced documents are solely each author's and should not be attributed to
EPA.
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AUTHOR INDEX
Allison, Richard C. E-3
Andrews, Richard N. F-4
Arthur D. Little, Inc. A-4, A-10, A-12, B-l, D-l, D-2,
D-7, F-4
Atkins, Patrick D-4
Barisas, Susan et.al. B-7
Barzotti, Joseph P. D-5
Basta, Michael F. D-8
Blakeslee, H. William B-3
Bleiweiss, Shell J. C-2
Brandwein, David D-2
Brookman, Gordon T. D-2
Cahill, Lawrence B. (editor) A-l
Capasso, Edward B-8
Case, David R. (editor) A-2
Christiff, Harold E-2
Cogen, Richard M. A-6, E-l
Cundall, Cheryl L. D-l
Cutler, Robert W. D-6, D-9
Danzig, Allen J. C-l, C-2
DiBerto, Maryanne A-l
Edward, James R. F-3
Eisen, Ellen A-13
Engineering-Science F-2
Environmental Law Institute C-3, F-2
Fahrenthold, Paul D. E-3
-ii-
-------
Fischer, Kenneth E. A-4
Fleckenstein, Leonard J. F-l
Ford, Mary Elizabeth A-6, E-l
Giannotti, David A. C-6
Gibson, Michael M. E-3
Goerth, Charles R. A-8
Goldsmith, Harold I D-4
Golob, Richard S. (editor) E-4
Grabowski, Theodore M. B-3
Greeno, J. Ladd A-l, B-6
Guida, Joseph A-11
Hall, Ridgway M. A-2
Harlow, Kirk C. E-3
Harrison, Lee (editor) A-2
Hedstron, Gilbert S. A-l, A-5
Henz, Donald J. C-6
Holtzclaw, Gary D. E-3
Kalagnaman, Ramesh E-2
Kane, Raymond W. (editor) A-l, E-2
Keller, James R. D-5
Kent, Thomas D. A-12, C-l
Kohm, Robert F. D-4
Krouse, Richard S. A-7
Levenstein, Charles A-13
Maclntyre, Stephen T. D-7
Marcus, Alfred A. B-8
-iii-
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Margolis, Joshua D. A-7
Mays, Richard c~4
MiIvy, Paul B-4
Nadel, Mark V. B-8
National Wildlife Federation A-9
Nemeth, John C. A-5
Palmisano, John A-10
Pearse, William M. D-5
Pico, Richard F. D-4
Plaut, Jonathan E-l
Policy Planning & Evaluation A-3, F-2
Pollard-Cavalli, Roberta D-3
Price, Courtney M. C-l, C-2
Raffle, Bradley I. C-4
Reed, John W. A-8, A-9
Reed, Phillip D. C-5
Renella, John R. E-2
Rhodes, Ralph L. B-5
Robertson, Edwin B. Jr. D-5
Roy F. Weston, Inc. B-4
Russell, David L. B-7
Sanela, D.A. A-6
Scheid, Daniel C. D-6
Shields, Jacqueline E-3
Singh, Jasbinder A-3
Smith, Martin A. A-7, D-8, F-3, F-4
-iv-
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Spiegel, Stuart J. D-l
Stiehl, Fred C-3
Strutz, Dennis E. A-7
TRC Environmental Consultants, Inc. B-2
Truitt, Thomas et.al. B-4
U.S. Air Force B-2
U.S. Department of Energy B-5
U.S. Environmental Protection Agency B-l, F-l
U.S. EPA Nat'l Enforcement Invest. Ctr. B-3
U.S. Sandia National Laboratories B-6
Walker, Michael J. C-l
Weiss, Malcolm C. A-10, C-5
Willborn, Walter A-11
Williams, John K. D-4
Young, R. Victor D-3
-v-
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A. GENERAL LITERATURE ON ENVIRONMENTAL AUDITING
Title: Environmental Audits
Authors: Lawrence B. Cahill (Ed.) with Raymond W. Kane
Doc. Type: Book (5th Edition, March 1987)
Abstract: Discusses the concept of environmental auditing; its evolution, and
advantages and disadvantages; perspectives of EPA and state
regulatory agencies, including EPA's Environmental Auditing Policy
Statement and the Agency's guidance on including audit provisions in
settlement agreements; legal issues such as confidentiality and
liability; planning and implementing an environmental audit program
and evaluating the results; and techniques and tools for training
auditors. Includes a section on international audits, a survey of
audit programs of 20 companies, sample questionnaires, and audit
checklists.
Source: Government Institutes Inc., 966 Hungerford Drive, #21, Rockville, MD
20850
Title: Environmental Auditing: Fundamentals and Techniques
Author: J. Ladd Greeno, Gilbert S. Hedstrom, and Maryanne DiBerto
Doc. Type: Book (1985) [Revised edition forthcoming: 1988]
Abstract: Addresses the emerging principles as well as the techniques of
environmental auditing, and provides practical guides to audit
program design and implementation. Includes appendices with audit
protocols and questionnaires for air and water pollution and solid
and hazardous waste management.
Source: Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn
Park, Cambridge, MA 02140.
A-l
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Title: Environmental Auditor
Author: Articles are contributed by various authors
Doc. Type: Professional Journal (Forthcoming May 1988)
Abstract: The journal is devoted to the applied practice of environmental
auditing, and is uultidisciplinary in approach. Its thesis is that
through environmental auditing, businesses can anticipate and manage
pollution control problems and related environmental concerns,
rather than being forced to react to crises as they occur. A typical
issue will examine legal, scientific, and economic problems and
solutions, and raise environmental issues for further analysis.
Source: Published by Springer International, Springer-?erlag New York, Inc.,
175 Fifth Avenue, New York, New York 10010. More information may be
obtained from Robert S. DeSanto, Editor-in-Chief, Environmental
Auditor. P.O. Box 3818, Hartford, CT 06103
Title: "Study of the Benefits of Environmental Auditing Provisions in
Enforcement Settlements"
Author: Jasbinder Singh, Policy Planning & Evaluation, Inc.
Doc. Type: Report (1988)
Abstract: Evaluates the effect of including environmental auditing provisions
in enforcement settlement agreements. Examines twenty settlement
cases requiring compliance and management audits and containing a
variety of settlement provisions. Demonstrates the benefits to
regulated entities, including improved environmental management
systems and business benefits; and identifies benefits to EPA,
including savings in inspection and enforcement resources, and
facilitation of follow-up inspections.
Source: Prepared for the Office of Enforcement Policy, U.S. EPA Office of
Enforcement and Compliance Monitoring, 401 M Street S.W.,
Washington, D.C. 20460
A-2
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Title: "Benefits to Industry of Environmental Auditing"
Author: Arthur D. Little, Inc., Center for Environmental Assurance
Doc. Type: Report (August 1983)
Abstract: Identifies principal objectives of environmental auditing programs
and analyzes expected benefits to firms adopting environmental
auditing programs. Benefits are categorized in terms of two main
effects: (1) increased management effectiveness, and (2) increased
management comfort or security that the company is meeting its
legal, corporate and ethical requirements. Identifies measures to
evaluate those effects.
Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from
the National Technical Information Service, U.S. Dept. of Commerce,
Springfield, VA 22161; NTIS No. PB85-240422-AS.
Title: "Safety in the Chemical Laboratory"
Author: Kenneth E. Fischer
Doc. Type: Periodical article
Abstract: Discusses the use of audits by many laboratories, including some in
colleges and universities, to ensure that their hazardous waste
handling operations are in compliance with state and federal
regulations. Covers areas common to both state and federal
regulations, including: waste determination; facility requirements;
use of the manifest; vendor, transporter and site selection
requirements; and training, contingency planning, and documentation.
References for checklists are provided.
Source: Journal of Chemical Education. September 1987, pp A207-A210
A-3
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Title: "Auditing Certification is no Guarantee for Quality Work"
Author: John C. Nemeth
Doc. Type: Periodical article
Abstract: Briefly discusses the issue of certification of environmental
auditors. Presents the idea that one individual may not be able to
handle the myriad of disciplines affected by a typical environmental
audit, making certification difficult. Raises, but doesn't resolve,
some regulatory issues involved in certification, such as licensing,
and competition among environmental auditing companies.
Source: Environmental Management News. September/October 1987, pg 17
Title: "Increased Assurance: The Response of Senior Management to Recent
Environmental, Health, and Safety Events"
Author: Gilbert S. Hedstrom
Doc. Type: Conference paper
Abstract: Reviews external and internal factors resulting in the development
of environmental auditing as an environmental management tool to
assure compliance. These factors include increased regulatory
enforcement, internal cost control, integration of environmental
health and safety programs, and decentralization. Describes the
characteristics of leading environmental, health, and safety audit
programs. Explores likely directions for this emerging discipline.
Source: The author is with Arthur D. Little, Inc., Acorn Park, Cambridge, MA
02140-2390. Presented at the Annual Meeting of the American
Institute of Chemical Engineers, August 24-27, 1986, Boston, MA.
A-4
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Title: "Who Should Conduct the Environmental Audit?"
Author: D. A. Samela
Doc Type: Conference paper
Abstract: Reviews definitions of environmental auditing and outlines the
elements of an effective environmental auditing system. Contrasts
the advantages and disadvantages of performing an in-house versus
using outside contractors. Concludes that well-established, larger
firms would benefit from in-house audits while smaller,
inexperienced firms may require external assistance. For any firm,
an outside audit is recommended when the firm's public image is at
stake.
Source: The author is with Stone and Webster Engineering Corporation, 250 W.
34th Street, 1 Penn Plaza, New York, NY, 10119. Presented at the
Annual Meeting of the American Institute of Chemical Engineers,
August 24-27, 1986, Boston, MA.
Title: "Using Environmental Auditing as an Affirmative Compliance Tool"
Authors: Mary Elizabeth Ford and Richard M. Cogen
Doc. Type: Conference paper
Abstract: Identifies and describes three major types of environmental audits
(pre-purchase, one-time or "snapshot", and continuing). Provides
constructive guidance regarding; (1) determining the need for an
environmental auditing program; (2) establishing an environmental
auditing program; (3) maintaining confidentiality of audit
information; (4) staffing the audit; (5) the use of checklist and
questionnaire; and (6) the audit follow-up. Concludes that a well-
implemented auditing program can aid a company in effectively making
a transition from a reactive to an affirmative environmental
compliance program.
Source: Published in the Proceedings of the Industrial Waste Symposium at
the 57th Annual Conference of the Water Pollution Control
Federation, September 30-October 1, 1984. The authors are with
Nixon, Hargrave, Devans, and Doyle, P.O. Box 1051, Lincoln First
Tower, Rochester, NY 14603.
A-5
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Title: "Environmental Audit Program Development."
Authors: Joshua D. Margolis, Dennis E. Strutz, and Richard S. Krouse
Doc. Type: Conference paper
Abstract: Presents overview and brief history of environmental auditing.
Provides questions about a company's current environmental
management program to use in determining the need for environmental
auditing. Discusses the different types and scopes of an EA
program, the advantages and disadvantages, and the issues that can
be addressed. Reviews procedures for staffing and organization.
Source: Mr. Margolis is with RMT/AER*X Division, 1625 I Street, NW, Suite
719, Washington, DC 20006. Presented at HazMat 1985, Philadelphia,
PA.
Title: "A Contingency View of Corporate Environmental Auditing and
Implications for Public Policy."
Author: Martin A. Smith
Doc. Type: University dissertation
Abstract: Analyzes the factors influencing management decisions on
environmental auditing. Compares characteristics of firms with
auditing programs to those without and investigates reasons to
establish programs, including efforts to meet societal
responsibilities, protect reputations, and cope with increased
complexity. Concludes that the major factor affecting the decision
to establish auditing programs is the complexity of corporate
environmental organization and activity.
Source: Submitted to the faculty of the Department of Environmental Sciences
and Engineering, University of North Carolina, Chapel Hill, NO,
1985.
A-6
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Title:
Author:
Doc. Type:
Abstract:
"The Environmental Audit: Friend or Foe?'
Charles R. Goerth
Periodical article
Presents the views of a number
environmental auditing, including
Explains that although an audit is
cite the company for any violations
company in its dealings with EPA.
effective auditing specified in EPA's
Statement", including support from
regularity, and clear reporting.
of experts in the field of
lawyers and EPA personnel.
no guarantee that EPA will not
uncovered, it will help the
Lists the seven conditions for
"Environmental Auditing Policy
top management, objectivity,
Source: Converting Magazine, pp 66-74, January 1987
Title: "Environmental Auditing: Practices in Canadian Industry"
Author: J.W. Reed
Doc. Type: Journal article
Abstract: Discusses the use of environmental auditing by Canadian firms as
part of their overall approach to environmental protection and
compliance assurance. Describes the results of a survey of the
Canadian industrial sector, including the fact that individual firms
use auditing programs to meet diverse objectives, such as verifying
compliance with environmental regulations, identifying environmental
risks and hazards, and limiting corporate liability.
Source: Pulp & Paper Canada. Vol. 88, No. 6, June 1987.
A-7
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Title:
Author:
Doc. Type:
Abstract:
Source:
Conservation Exchange
National Wildlife Federation
Newsletter
Several articles in the newsletter's Fall 1987 issue addressed
different aspects of environmental auditing. Among aspects
discussed are: the institutionalization of environmental auditing
within industries; formation of environmental auditing
organizations; reasons for popularity; benefits; and the lack of
national certification standards for environmental auditors.
Recommends industry efforts to establish uniform educational and
professional standards for the field. Speculates that federal
legislation mandating environmental auditing for regulated entities
is not likely in the near future. Discusses the efforts of a few
states to use legislative leverage to encourage environmental
auditing.
Conservation Exchange. Vol. 5, No. 1, Fall 1987.
National Wildlife Federation, 1412 Sixteenth St.
D.C. 20036
Published by the
N.W., Washington,
Title:
Author:
Doc. Type:
Abstract:
Source:
"Environmental Auditing: A Review of Current Practice"
John W. Reed
University thesis
Describes environmental auditing and its roles and objectives in
industry, drawing comparisons between EA and financial auditing.
Defines the characteristics of audits with particular emphasis on
management structure within the company conducting audits. Benefits
of audits are seen to be an increased awareness of environmental
regulations which would culminate in increased environmental
protection. Disadvantages are seen primarily to be the newness 6f
EA, and the misunderstanding of ideas. Identifies disclosure and
confidentiality as issues that may be a disincentive to auditing.
Submitted to York University. March 1984. Resource Center, Faculty
of Environmental Studies, York University, 333 Lumbers Building,
1P3. Also available from Publications,
Environment Canada, Ottawa Ontario K1A
Reed is with Texaco, Canada Inc., 1210
North York, Ontario M3J
Conservation and Protection,
OE7 (Pub. Ref. f IP-17). Mr.
Sheppard Ave. East, Willowdale, Ontario M2K 2S8.
. A-8
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Title: "Environmental Auditing: An Overview"
Author: Arthur D. Little, Inc., Center for Environmental Assurance
Doc. Type: Report (1983)
Abstract: Describes the different functions and objectives which
private-sector environmental auditing can serve. Develops an audit
process designed to create an audit report giving corporate managers
reliable information on which to base decisions.
Source: Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn
Park, Cambridge, Massachusetts, 02140. Presented at Seminar on
Private Sector Environmental Auditing, February 15, 1983,
Washington, DC.
Title: "Environmental Auditing: What Is It?"
Author: John Palmisano and Malcolm C. Weiss
Doc. Type: Journal article
Abstract: States that different professional groups, each vying for auditing
accounts, impart to it different attributes promoting their own
interests. Notes three myths about auditing: (1) disclosure
problems outweigh the benefits gained by auditing; (2) benefits
derived from auditing are primarily psychological, not financial;
and (3) small businesses cannot adopt auditing because costs are
prohibitively high.
Source: Environmental Analyst; Vol.4, N6.ll, November 1983, pp. 13-17. Mr.
Palmisano and Mr. Weiss are with RMT/AER*X Division, 1625 I Street,
NW, Suite 719, Washington, D.C. 20006.
A-9
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Title: "Compendium of Audit Standards"
Author: Walter Willborn
Doc. Type: Report (1983)
Abstract: Summarizes existing audit standards and guidelines issued by: the
Institute of Internal Auditors, the American Institute of CPAs,
Canadian Standards Association, ANSI/ASME, Government of Canada, and
the U.S. General Accounting Office. Emphasizes commonalities among
these standards. Addresses general features of audit standards and
major audit issues such as: auditor requirements, organization,
audit planning and procedures, audit reports, audit completion, and
quality assurance.
Source: American Society for Quality Control, 230 W. Wells Street,
Milwaukee, Wisconsin 53203.
Title:
Author:
Doc. Type:
Abstract:
Source:
"A Practical Look at Environmental Audits"
Joseph Guida
Journal article
Discusses the rise of the audit trend and advantages gained by using
an auditing system. Broadly defines different approaches available
to corporations instituting auditing programs. Concludes** that the
strategy employed by a particular firm is dependent upon the
characteristics of that firm and the type of data corporate officers
desire.
Journal of the Air Pollution Control Association.
August 1982, pp. 568+.
Vol. 32, No.5,
A-10
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Title:
Author:
Doc. Type:
Abstract:
Source:
"Internal Environmental Review Programs — Pitfalls and Benefits"
Thomas D. Kent
Journal article
Allied Corporation's associate general counsel argues that using the
term "audit" to describe internal environmental review programs
might increase the risk of legal sanctions for negligent
interpretations. Describes the genesis of the "environmental
surveillance" program at Allied. Points out possible pitfalls in
such programs, which are outweighed by far by the benefits. States
that an ounce of cost-effective prevention in addition to making one
feel good, is far better than a pound of lawsuits, negotiated or
imposed cleanup schedules, and headaches.
Journal of the Water Pollution Control Federation,
57, No. 3, pp. 191-195.
March 1985, Vol.
Title: "Benefits of Environmental Auditing: Case Examples"
Author: Arthur D. Little, Inc., Center for Environmental Assurance .
Doc. Type: Report (December 1984)
Abstract: Documents the benefits of environmental auditing as reported by
managers responsible for their organizations', environmental audit
program. In some cases, the examples illustrate actual benefits
derived form individual audits, while in other cases the benefits
result from having conducted a number of audits over a period of
time. Provides insights into how environmental auditors conduct
their field work, what type of situations they are likely to
uncover, and how facility-level environmental management can improve
as a result of an audit.
Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from
the National Technical Information Service, U. S. Dept. of Commerce,
Springfield, VA 22161; NTIS No. PB85-239531-AS.
A-ll
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Title: "Certified Environmental Audits: A Proposal"
Authors: Ellen Eisen and Charles Levenstein
Doc. Type: Conference paper
Abstract: Proposes the development of an independent and certified compulsory
environmental auditing system for all foreign facilities of any U.S.
company raising domestic funds. Suggests that funders would serve
as source of pressure for compliance with environmental regulations.
Compares the World Bank compulsory audit system with EPA's voluntary
approach, and proposes a model similar to the World Bank's.
Source: Dr. Eisen is Asst. Prof, of Occupational Health, Harvard School of
Public Health, Boston, MA 02115. Dr. Levenstein is Visiting Prof.
of Management, Center for Productivity Enhancement, University of
Lowell, Lowell, MA 01854. Presented at the Annual Meeting of the
American Association for the Advancement of Science, May 30, 1986,
Philadelphia, PA.
A-12
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B. AUDIT SYSTEM DESIGN AND METHODOLOGY
Title: "Environmental Auditing Skills and Techniques Workbook"
Author: Arthur D. Little, Inc., for the Edison Electric Institute
Doc. Type: Manual (1987)
Abstract: Provides the field auditor with the basic skills and techniques
needed to conduct an effective audit. Topics include the use of
audit protocols and working papers; the interview process and ways
to increase its effectiveness; understanding and assessing internal
controls of the organization; sampling techniques; and evaluating
audit results and reporting the findings. The workbook includes a
comprehensive glossary of auditing terms.
Source: Edison Electric Institute, Environmental Auditing Task Force, 1111
Nineteenth St. N.W., Washington, D.C. 20036
Title: Environmental Audit Protocol for EPA Facilities (Final Draft)
Author: U.S. Environmental Protection Agency
Doc. Type: Manual (November 1986)
Abstract: Protocol intended to serve as a guide for auditors to plan and
conduct environmental audits at EPA facilities. Consists of four
major sections: (1) Pre-audit activities (e.g. notification review
of background information, agency contacts); (2) Understanding
management systems (e.g. review of audit plan); (3) Gathering audit
evidence (on different environmental areas); (4) Evaluating evidence
and reporting findings. Includes observation checklist for air and
water pollution, spill prevention, and hazardous waste management.
Includes complete questionnaire.
Source: Environmental Compliance Program, Occupational Health and Safety
Staff (PM-273), U.S. Environmental Protection Agency, 401 M Street
SW, Washington, DC 20460.
B-l
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Title:
Author:
Doc. Type:
Abstract:
A Procedure for Evaluating Hazardous Waste Vendors
for Edison Electric Institute,
TRC Environmental Consultants, Inc.
Environmental Auditing Task Force.
Manual (1986)
Manual for use by an electric utility company to understand the
benefits and purposes of auditing hazardous waste contractors,
particularly to reduce waste generator liability. Reviews use of
audit questionnaires that assess technical, financial, and
management aspects of vendors to determine risk potential.
Discusses alternative approaches to performing audits, and includes
sample facility site audit (35 pp), telephone audit (4 pp), and
property transfer audit (30 pp).
Source: Edison Electric Institute, 1111 19th Street NW, Washington DC 20036.
Title:
Author:
Doc. Type:
Abstract:
Source:
Environmental Compliance
Guidance Manual
Assessment and Management Program (ECAMP):
U.S. Air Force
Manual (1986)
A protocol manual for conducting internal audits to assess the
environmental compliance status of Air Force installations.
Summarizes Federal, state, and local regulations, lists key
compliance requirements, and provides protocol checklist for the
following compliance categories: air emissions; wastewater
discharge; solid and hazardous waste management;
pesticides/herbicides; PCB management; drinking water; POL
management; and hazardous materials management.
Major Roy Solomon, AF/LEEV, Boiling Air Force Base, Washington, DC,
20332-5000. Availability of this document may be limited.
B-2
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Title: A Practical Guide to Plant Environmental Audits
Author: H. William Blakeslee and Theodore M. Grabowski
Doc. Type: Book (1985)
Abstract: Provides step-by-step advice on auditing a plant's compliance for
air, water, waste, oil spills, toxic substances and others.
Provides information for the engineer responsible for compliance,
especially at small and medium-sized manufacturing and chemical
plants.
Source: Van Nostrand Rheinhold Company, Inc., 135 West 50th Street, New
York, NY, 10020. Mr. Blakeslee is with CertainTeed Corporation,
1400 Union Meeting Road, Blue Bell, PA 19422. Mr. Grabowski is with
Sun Refining and Marketing Company.
Title:
Author:
Doc. Type:
Abstract:
Source:
Multi-Media Compliance Audit Procedures
EPA National Enforcement Investigations Center
Manual (June 1987)
Details the procedures used by EPA or state inspectors authorized to
conduct multi-media compliance inspections of facilities. The
approach is intended to more effectively schedule the time of
investigatory personnel and support a rational system for analyzing
the compliance status of particular sources. Discusses the roles
and responsibilities of inspectors.
U.S. EPA, National Enforcement Investigations Center, Federal
Center, Bldg. 53, Box 25227, Denver, Colorado 80225. EPA Report No.
EPA-330/9-87-001-R
B-3
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Title:
Author:
Doc. Type:
Abstract:
Source:
Environmental Audit Handbook:
Compliance Auditing
Basic Principles of Environmental
Thomas H. Truitt, et. al.
Book (1983)
Comprehensively addresses the managerial, legal and procedural
elements necessary to produce a quality environmental audit. The
audit is characterized as a way to measure a plant's compliance
performance against regulatory standards. Includes a lengthy
section on planning and conducting audits as well as evaluating the
data generated. Addresses legal issues arising from potential
disclosure of audit information under SEC and major federal
environmental regulations.
Executive Enterprises Publications Co., Inc., 33 West 60th Street,
New York, NY, 10023. Mr. Truitt is with Wald, Harkrader & Ross,
1300 Nineteenth Street NW, Washington DC, 20036
Title: "Applicability of Environmental Auditing to Underground Storage
Tanks"
Author: Roy F. Weston, Inc.
Doc. Type: Draft report (1986)
Abstract: Identifies recent Federal, state, and local regulatory initiatives
for underground storage tanks. Summarizes and describes auditing
procedures applicable to tank assessment and management systems.
Includes sample audit check lists for underground storage tanks.
Source: Prepared for the Regulatory Reform Staff, PM-223, EPA, 401 M Street,
SW, Washington, DC 20460.
B-4
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Title: "Reporting Environmental Audit Findings"
Author: Ralph L. Rhodes
Doc. Type: Conference paper
Abstract: Discusses factors to be considered in assuring effective
communication of environmental auditing results, including: (1)
fundamental principles of effective communication; (2) appropriate
reporting and confidentiality of information, and (3) opportunity
for additional communication.
Source: The author is with Allied-Signal, Inc. PO Box 2332R, Morristown,
NJ, 07960. Presented at the Annual Meeting of the American
Institute of Chemical Engineers, August 24-27, 1986, Boston, MA.
Title: The Environmental Survey Manual
Author: U.S. Department of Energy
Doc. Type: Manual (August 1987)
Abstract: Provides guidance to the U.S. Department of Energy's Survey &
Sampling and Analysis teams conducting a one-time environmental
survey of major DOE operating facilities. [This survey differs from
an environmental audit: an audit is generally characterized as a
regulatory compliance check that may also involve a review or
critique of management systems. In contrast the Survey is a
compilation or inventory of environmental problems for purposes of
prioritization.J The various sections of the manual deal with:
procedures and protocols to be used by the Survey teams; criteria to
evaluate existing environmental data; generic technical checklists;
health and safety guidelines for the personnel conducting the
Survey; required formats for the Survey reports; issues of problem
identification and prioritization; and sampling and analysis
techniques.
Source: U.S. Department of Energy, Office of the Assistant Secretary
Environment, Safety, & Health, Office of Environmental Audit, 1000
Independence Ave., S.W., Washington, D.C. 20585. Available from the
National Technical Information Service, U.S. Department of Commerce,
Springfield, VA 22161. Ref. No. DOE/BH-0053
B-5
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Title: "An Approach to ES & H Assurance Programs for Institutions"
Author: Sandia National Laboratories, Andrew Ellingson and Charles Trauth,
Jr., editors
Doc. Type: Report (September 1982)
Abstract: A collection and condensation of material contained in 17 separate
Sandia National Laboratories' publications concerning Environmental,
Safety and Health (ES&H) programs. Provides a detailed description
of the components of an ES&H program including assurance, staff
review activities and appraisals, institutional emergency response
programs and institutional accident investigations.
Source: Prepared by Sandia National Laboratories, Albuquerque, New Mexico
87185. Volume I: Institutional ES&H Staff Functions available from
National Technical Information Service, U.S. Dept. of Commerce,
Springfield, VA 22161; NTIS No. DE-83-004254.
Title: "Increasing the Effectiveness of Environmental Auditing Programs"
Author: J. Ladd Greeno
Doc. Type: Conference paper
Abstract: Examines the impact of various program design and implementation
considerations on the effectiveness of an audit program. Audit
objectives, approach and staffing are key determinants of the
effectiveness of an environmental audit program. It is important
that these three aspects of the design and implementation of an
audit program be congruent and mutually supportive.
Source: Mr. Greeno is with the Center for Environmental Assurance, Arthur D.
Little, Inc., 15 Acorn Park, Cambridge, MA 02140. Presented at the
78th Annual Meeting of the Air Pollution Control Association, June
18, 1985.
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Title: "Managing Your Environmental Audit"
Author: David L. Russell
Doc. Type: Periodical article
Abstract: Discusses problems frequently uncovered during an audit and tips for
conducting an audit. Suggests what a facility manager should
consider before, during, and after an audit of his operations is
conducted and what to do if serious problems are uncovered.
Source: Chemical Engineering. June 24, 1985, pp. 37-43.
Title: Environmental Protection Appraisals: A Suggested Guide for U.S.
Department of Energy Field Organizations, and
Internal Environmental Protection Audits: A Suggested Guide for
U.S. Department of Energy Facilities.
Author: Susan Barisas, et al.
Doc. Type: Audit Manual (August 1983) and Appraisal Manual (March 1985)
Abstract: Prepared for use by DOE facilities as aids for conducting internal
environmental protection audits and on-site operating level
appraisals. Consist of sets of audit questions organized with
respect to specific areas of environmental protection (e.g.,
nonradioactive air pollution, asbestos, radio-nuclides, toxic
substances, PCB materials, hazardous waste, laboratory quality
assurance). Develops questions within each specific area from
existing DOE orders, executive orders, federal statutes and
regulations. Provide methodologies which have the potential to be
used by facilities other than DOE's.
Source: Argonne National Lab (Reports tANL/EES-TM-237 and ANL/EES-TM-264),
Energy and Environmental Systems Division, Integrated Assessment and
Policy Evaluation Group, 9700 S. Cass Ave., Argonne, IL, 60439.
B-7
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Title: "Technical Considerations in Conducting a Hazardous Waste Facility
Audit"
Author: Edward Capasso
Doc. Type: Conference paper
Abstract: Discusses technical aspects to be considered in conducting an audit
at a company-owned hazardous waste storage facility. Elements of an
effective audit include management and team support, team
objectivity, audit boundaries, and review procedures and follow-ups.
Also presents procedures within the audit that should be given
special attention.
Source: .The author is with Troy Chemical Corporation, 1 Avenue L, Newark NJ,
07105. Presented at HAZPRO, April 1986, in Baltimore MD.
Title: "Can You Trust Your Environmental Auditing Program?
Author: Alfred A. Marcus and Mark V. Nadel
Doc. Type: Report (November 1983)
Abstract: Discusses organizational issues affecting environmental audits and
whether managers can have faith in the capability and integrity of
their auditing programs. Suggests factors managers may take into
account when establishing or upgrading audit programs. Because so
many variables exist with in a firm regarding audit systems,
managers should take a position allowing them to evaluate evolving
programs and make corrections when appropriate.
Source: Prepared for Regulatory Reform Staff, U.S. EPA. Available from
National Technical Information Service, U.S. Dept. of Commerce,
Springfield, VA 22161; NTIS No. PB 85-240166-AS.
8-8
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C. CONFIDENTIALITY. DISCLOSURE, and OTHER LEGAL ISSUES
Title: "Environmental Auditing: Reaching the Bottom Line in Compliance"
Authors: Allen J. Danzig, Michael J. Walker, and Courtney M. Price
Doc. Type: Journal Article
Abstract: Describes EPA's efforts to encourage environmental auditing by
regulated entities. Discusses the evolution of government and
corporate interest in environmental auditing and its benefits; EPA's
efforts to promote environmental auditing through policy statements;
and major settlement agreements under TSCA and RCRA that contain
environmental auditing provisions. Concludes that audit programs
save money for regulated entities in the long run, and create an
atmosphere of improved cooperation with regulated entities, while
complementing the letters' compliance efforts.
Source: National Environmental Enforcement Journal. Vol. 2, No. 1, January
1987, pp 3-14. Published by the National Association of Attorneys
General, Suite 403, 444 North Capitol St., Washington, D.C. 20001
Title: "Risk of "Smoking Gun" Papers is Outweighed by the Benefits"
Author: Thomas D. Kent
Doc. Type: Periodical article
Abstract: Focuses on the environmental compliance programs at a particular
company, Allied-Signal Inc. Describes the corporate-wide
"Environmental Surveillance Program", which is the company's term
for an environmental audit program. Raises the issue of potential
penalties and liabilities arising out of accidental release of
reports prepared as part of the program; and suggests vays to
minimize the risk of potential damage to the company. Concludes
that the economic, safety, and health benefits of such a program
outweigh the risk of being found in non-compliance with regulations.
Source: Preventive Law Reporter. Vol. 6, No. 3, pp 12-16, September 1987
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Title: "Legal Considerations in Environmental Audit Decisions"
Author: Shell J. Bleiweiss
Doc. Type: Periodical article
Abstract: Discusses the legal benefits of conducting environmental audits
including assuring corporate compliance at the plant level, reducing
potential liability, and improving public relations. Audits can
also be critical factors in negotiating the sale or acquisition of
property or stock. Concludes that audits must be carefully planned
to maximize credibility while protecting confidential and
potentially damaging information.
Source: Chemical Engineering Process. January 1987, pp 15-19
Title: "Environmental Auditing: Developing a 'Preventative Medicine'
Approach to Environmental Compliance"
Authors: Courtney M. Price and Allen J. Danzig
Doc. Type: Journal article
Abstract: Reviews EPA effort to encourage use of environmental auditing and
development of EPA auditing policy with emphasis on Agency access to
audit results. Explores the evolution of corporate interest in
environmental auditing and identifies benefits gained by firms
instituting auditing programs. Includes major settlement agreements
containing environmental auditing provisions.
Source: Loyola of Los Angeles Law Review. Vol. 19, No. 4, pp. 801-824, 1986.
Ms. Price is a partner with Rivkin, Radler, Dunne, and Bayh, 1575 I
St., NW, Suite 1025, Washington DC 20005. Mr. Danzig is Special
Assistant to the Assistant Administrator for Enforcement and
Compliance Monitoring, U.S. EPA.
C-2
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Title: "Environmental Auditing"
Author: Fred Stiehl
Doc. Type: Conference paper
Abstract: Reviews state and federal approaches to the concept of environmental
auditing and principles governing EPA's use of auditing in
enforcement programs. Addresses two main concerns expressed in
public comments to EPA's programs: (1) EPA request for audit
reports and (2) potential use of audits in enforcement actions.
Discusses current issues EPA is evaluating that will affect use of
environmental auditing in enforcement settlements.
Source: The author is with the Office of Enforcement and Compliance
Monitoring, LE-134S, EPA, Washington, DC, 20460. Presented at
HAZPRO, April 1986, Baltimore, MD.
Title: "Duties to Report or Disclosure Information on the Environmental
Aspects of Business Activities"
Author: Environmental Law Institute
Doc. Type: Report (September 1985)
Abstract: Delineates corporate obligations to record and report information on
the environmental and health impacts of their activities and EPA
obligations to disclose or protect such information. Examines: (1)
selected statutes and regulations; (2) SEC requirements; (3) common
law; (4) ethical obligations under professional codes of conduct,
and (5) EPA's obligations to report compliance information to the
public. Lays out the factual background for EPA examination of
environmental audit policy options.
Source: Prepared for the Regulatory Reform Staff, PM-223, EPA, 401 M St.,
SW, Washington, DC 20460.
C-3
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Title: "Corporate Environmental Compliance Programs"
Author: Bradley I. Raffle
Doc. Type: Conference paper
Abstract: Discusses legal issues presented by corporate environmental quality
assurance (audit) programs. Concludes that the benefits associated
with these programs outweigh any legal concerns. As environmental
compliance costs and liabilities escalate, such programs should gain
even broader acceptance. Development would be advantageous to the
public and environmental enforcement agencies as well as to the
companies that implement the programs.
Source: Mr. Raffle is Supervising Counsel with Conoco, Inc., PO Box 2197,
Houston, TX 77079. Presented at the 78th Annual Meeting of the Air
Pollution Control Association, June 18, 1985.
Title: "Environmental Audits: Addressing Root Causes"
Author: Richard Mays
Doc. Type: Periodical article
Abstract: An EPA enforcement attorney presents his personal views on the value
of negotiating environmental auditing provisions in certain
out-of-court settlements. By doing so, EPA would go beyond
addressing only the outward manifestations of the problem (the
violation) and respond to what may be the root cause of
noncompliance: lack of adequate environmental policies and
procedures.
Source: Chemical Week. May 29, 1985, pp. 3-4.
C-4
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Title: "Can What You Know Hurt You as Much as What You Don't Know?"
Author: Phillip D. Reed
Doc. Type: Journal article
Abstract: Suggests that increases in industrial auditing programs indicate a
maturity of pollution control laws. Asserts that although industry
is accepting environmental compliance, there are concerns about
legal consequences and confidentiality of audit reports. Reviews
EPA policy governing access to audits and questions use of audits in
administrative enforcement actions.
Source: Environmental Law Reporter. Vol. 13, No. 10, October 1984, pp.
10303-8. Mr. Reed is with the Environmental Law Institute, 1346
Connecticut Avenue NW, Washington, DC 20036.
Title: "Issues of Confidentiality and Disclosure In Environmental Auditing"
Author: Malcolm C. Weiss
Doc. Type: Paper (April 1984)
Abstract: Presents and analyzes legal issues surrounding the confidentiality
of environmental audit generated information. Addresses the
confidentiality and disclosure issues by examining to what extent
audit information, if disclosed, could adversely affect its
producer; and legal principles and developing case law which may be
useful in securing legitimate confidentiality of audit information.
Source: Prepared by Mr. Weiss while a member of the Regulatory Reform Staff,
U.S. EPA. Available from the National Technical Information
Service, U.S. Dept. of Commerce, Springfield, VA 22161; NTIS No.
PB85-239259-AS.
C-5
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Title: "Safeguarding Confidential Business Information"
Author: Donald J. Henz
Doc. Type: Conference paper
Abstract: Suggests that certain information generated from an environmental
auditing program will have to made confidential. Identifies
auditing data that may be used against a company, including
information on capacity, production rates, process flow, expected
life of facilities, and expenditures. Discusses methods to enhance
confidentiality of data in the context of two rules: (1) never
volunteer information and (2) maintain a confidential mentality.
Source: PEDCO Environmental, Inc. 11499 Chester Road, Cincinnati, OH 45246.
Presented at the 76th Annual Meeting, Air Pollution Control
Association, June 1983, Atlanta, GA.
Title: "Environmental Auditing and Inspections"
Author: David A. Giannotti
Doc. Type: Report chapters
Abstract: Describes the elements of an environmental auditing program
including: company description, policy and organization,
categorization of facilities, internal procedures for reporting
environmental matters, and issues with unascertainable aspects.
Discusses the issue of disclosure, concentrating on attorney-client
privilege and the work product doctrine. Asserts that
communications between an attorney and a client may be kept
confidential, depending on how "client" is defined.
Source: Report prepared for inclusion in Organizing Corporate Compliance
Efforts (American Bar Association, June 1983) and Environmental
Compliance in a Changing Legal Environment (Practicing Law
Institute, New York; Sept. 1983.) Mr. Giannotti is with Occidental
Petroleum Corporation, 10889 Wilshire Blvd., Los Angeles, CA 90024.
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D. INDUSTRY EXPERIENCE AND PERSPECTIVES
Title: "Case Studies in Environmental Audits: A Practical Focus for Plant
Managers and Auditors"
Author: Stuart J. Spiegel and Cheryl L. Cundall
Doc. Type: Conference paper
Abstract: Argues that the objective of environmental audits is to evaluate
procedures and practices that could results in systematic
contamination, rather than to detect the potential for severe,
one-time catastrophic releases. Includes four case studies which
demonstrate the variety of problems that can be identified through
an audit. \
Source: The authors are with O'Brien and Gere Engineers, Inc., P.O. Box
4873, Syracuse, NY 13221. Presented at the Annual Meeting of the
American Institute of Chemical Engineers, August 24-27, 1986,
Boston, MA.
Title: "Current Practices in Environmental Auditing"
Author: Arthur D. Little, Inc., Center for Environmental Assurance
Doc. Type: Report (February 1984)
Abstract: Discusses environmental auditing to further the understanding of how
various companies approach the subject. Describes five individual
environmental audit programs based on in-depth interviews with the
companies' audit program managers. The companies interviewed
represent a diversity of audit approaches and have made significant
commitments to their auditing efforts. Includes program
documentation, e.g. checklists, protocols, and audit reports, to
illustrate the nature and scope of each program.
Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from
the National Technical Information Service, U.S. Dept. of Commerce,
Springfield, VA 22161. NTIS No. PB-240125-AS.
D-l
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Title: "Environmental Auditing Case Studies"
Author: Arthur D. Little, Inc., Center for Environmental Assurance, for the
Edison Electric Institute
Doc. Type: Report (1984)
Abstract: Similar to "Current Practices in Environmental Auditing", this
publication focuses on environmental auditing systems in the
electric utility industry- Descriptions of five electric utility
companies' audit programs are presented in considerable detail.
Source: Edison Electric Institute, Environmental Auditing Task Force, 1111
Nineteenth Street NW, Washington, DC 20036.
Title: "The Most Common Sins Discovered During Environmental Audits"
Authors: David Brandwein and Gordon T. Brookman
Doc. Type: Conference paper
Abstract: Discusses the fourteen most common deficiencies discovered during
audits conducted at more than 150 industrial operations in 30
states. Findings include inadequate waste containment, insufficient
inspection of storage areas, lack of SPCC plan, and incomplete
analysis of wastewaters. Concludes that many problems can be solved
by better management practices and procedures rather than major
capital improvements.
Source: The authors are with Environmental Risk, Ltd., 120 Mountain Ave.,
Bloomfield, CT, 06002. Presented at the Annual Meeting of the
American Institute of Chemical Engineers, August 24-27, 1986,
Boston, MA.
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Title: "Another Approach to Environmental Auditing"
Author: R. Victor Young
Doc. Type: Conference paper
Abstract: Traces the development of ARCO's environmental audit program and
describes criteria for an effective audit, including management
commitment; review scope, staffing, schedule, procedures, and
reports; follow-up; and documentation. ARCO's unique approach
involves two levels of assurance: each division is given
responsibility to conduct environmental audits, and there is an
oversight corporate audit of the operating company's review
programs.
Source: The author is with the Atlantic Richfield Company, 515 South Flower
Street, Los Angeles, CA, 90071. Presented at the Annual Meeting of
the American Institute of Chemical Engineers, August 24-27, 1986,
Boston, MA.
Title: "Corporate Experience in Environmental Auditing"
Author: Roberta Pollard-Cavalli
Doc. Type: Conference Paper
Abstract: Traces the development of Celanese Chemical Company's environmental
auditing program. Details the objectives and format of the auditing
process. Describes key factors influencing the effectiveness of an
audit program, particularly the independence and authority of the
auditor. Includes the Celanese audit policy and an environmental
review checklist.
Source: The author is with Celanese Chemical Company, PO Box 47320, Dallas,
TX 75247. Presented at the Environmental Law Implications of
Business Activities Conference, November 7-8, 1985, Southern
Methodist University School of Law.
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Title: "Internal Environmental Audits - Assuring Compliance with the
Regulations"
Authors: Harold I. Goldsmith, Richard F. Pico, and John K. Williams
Doc. Type: Conference paper
Abstract: Case history of Kraft's efforts to insure that individual locations
comply with basic environmental regulations. Areas reviewed in each
plant include: Wastewater discharges, spill prevention control and
counter-measure plans, water supply, air emissions, other wastes and
OS HA. Describes training and use of non-environmental
professionals. Includes auditor's checklist.
Source: The authors are with Kraft, Inc., Kraft Court, Glenview, IL 60025.
Presented at the 58th Annual Conference of the Water Pollution
Control Federation, October 6-10, 1985, Kansas City, Missouri.
Title: "Environmental Auditing - A Management Tool"
Author: Patrick Atkins and Robert F. Kohm
Doc. Type: Conference paper
Abstract: Discusses environmental auditing as implemented within the Aluminum
Company of America (Alcoa) and focuses on auditing as a management
tool. Covers the auditing program from conceptualization to current
implementation. Concludes that auditing has proven to be an
effective tool for improving environmental management even while on
going changes.
Source: The authors are with Aluminum Company of America, 1501 Alcoa
Building, Pittsburgh, PA 15219. Presented at the annual meeting of
the Environmental Division of the American Society of Civil
Engineers, July 3, 1985.
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Title: "General Motors Environmental Auditing Experience"
Author: Joseph P. Barzotti and James R. Keller
Doc. Type: Conference paper
Abstract: Traces the development of and explains the auditing operation within
General Motors Environmental Activities Staff. The audit program's
focus is on prevention of problems. Its goal is to assure that all
GM facilities achieve and maintain compliance with current and
projected environmental laws, regulations and GM standards. Audit
teams help share solutions to common problems among GM facilities.
Self-identification of problems has enhanced the Corporation's
reputation with government agencies at the local, state and federal
levels.
Source: The authors are with General Motors Corporation, General Motors
Technical Center, Warren, MI 48090. Presented at the 78th Annual
Meeting of the Air Pollution Control Association, June 18, 1985.
Title: "Environmental Auditing — TVA's Experience"
Author: Edwin B. Robertson, Jr., and William M. Pearse
Doc. Type: Conference Paper
Abstract: TVA's auditing experience has been very satisfactory and auditing
has become an important element of facility environmental
management. Facilities and operations are audited against
legislation, regulation, TVA policy, organization procedures,
specific permits, NEPA documents and commitments to regulators. The
program serves as a tool for regular intra-agency communication.
Describes TVA's auditing process and one operating organization's
reception to the program.
Source: Mr. Robertson is Environmental Scientist, Environmental Quality
Staff with the Tennessee Valley Authority, Muscle Shoals, AL 35660.
Presented at the annual meeting of the Environmental Division of the
American Society of Civil Engineers, July 3, 1985.
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Title: "Union Carbide Corporation's Health, Safety, and Environmental
Protection Program"
Author: Daniel C. Scheid
Doc. Type: Conference paper
Abstract: Describes the objectives, organization, staffing, scope, and
reporting aspects of the corporate internal audit program developed
by Union Carbide with the assistance of Arthur D. Little, Inc.
Focuses on the compliance audits, used to determine compliance
status of operating locations with respect to governmental and
internal requirements. Outlines the audit methodology, including
understanding and assessing management systems; and gathering,
evaluating, and reporting audit findings.
Source: The author is with Union Carbide Corporation, Old Ridgebury Road,
Danbury, CT 06817. Presented at the Annual Meeting of the American
Institute of Chemical Engineers, August 24-27, 1986, Boston, MA.
Title:
Author:
Doc. Type:
Abstract:
Source:
"Self-Auditing Program Monitors Compliance"
Robert Cutler
Periodical article
Robert Cutler of Olin Corporation discusses environmental auditing
based on his experience as manager of the Regulatory Compliance
Audit Department. He believes a successful audit program requires
(a) good people, (b) analysis of the regulatory requirements
applicable to a company's operations, and (c) that the auditing
office be kept independent of the activities being audited.
Hazardous Waste and Pollution Management Bulletin.
February 10, 1983, pp 1-2.
Vol. 1, B303,
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Title: "Profiles of Environmental Auditing Programs"
Author: Arthur D. Little, Inc.
Doc. Type: Report (1980)
Abstract: Surveys provided the information from which profiles of 17
corporations' environmental auditing programs comprising this report
are drawn. The profiles show a diversity and creativity of auditing
models. The implications of the profiles are discussed in a
companion piece, "A Survey of Environmental Auditing."
Source: Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn
Park, Cambridge, Massachusetts, 02140.
Title: "Environmental Auditing - A Timely and Effective Tool"
Author: Stephen T. Maclntyre
Doc. Type: Journal article
Abstract: Defines environmental auditing; discusses auditing approaches
currently being utilized by some Fortune 100 companies; reviews some
of the potential benefits and liabilities associated with
environmental auditing; and suggests that the benefits to be derived
from auditing are enough of an incentive that industry
representatives should work with regulators to enhance its
potential.
Source: Journal of the Air Pollution Control Association. Vol. 33, No. 9,
Sept. 1983, pp. 909-913. Mr. Maclntyre is with Rochester Gas and
Electric Corporation, 89 East Avenue, Rochester, NY 14649.
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Title: "A Utility's Experience With An Environmental Quality Assessment
Program"
Author: Michael F. Basta
Doc. Type: Conference paper
Abstract: Details the background, scope and design of the Pennsylvania Power
and Light (PP&L) auditing program to achieve environmental
compliance at its facilities. Explains the auditor's role as
providing management assistance to the line organization so they may
carry out the company's policies. Examines how two key business
documents supply guidance, the assessment process and follow-up
response. PP&L advocates auditing as a way that industry can take a
leadership role in helping to improve the environmental regulatory
process.
Source: Pennsylvania Power and Light Company. Two North Ninth Street,
Allentown, Pennsylvania, 18101. Presented at the 76th Annual
Meeting of the Air Pollution Control Association, June 1983,
Atlanta, Georgia.
Title: "Environmental Auditing Policy: An Exploratory Analysis from the
Corporate Perspective"
Author: Martin A. Smith
Doc. Type: University paper (May 1983)
Abstract: Examines how corporations might respond toward environmental
auditing as a tool to achieve management goals, both for corporate
activities related to the environment and for the company as a
whole. Establishes three general categories as policy alternatives:
(1) traditional non-auditing controls; (2) informal auditing; and
(3) formal auditing. These categories form the vertical component
of a matrix employing "criteria for choice" as the horizontal
component. Concludes that after costs and benefits are weighed,
corporate policy should include formal auditing as a management
tool.
Source: Institute for Environmental Studies, University of North Carolina
311 Pittsboro Street 256H, Chapel Hill, North Carolina 27514.
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Title: "Environmental Auditing: The Keystone to a Management Compliance,
Control and Risk Assessment Program"
Author: Robert W. Cutler
Doc. Type: Journal article
Abstract: Establishes a framework and analyzes characteristics of a viable
environmental auditing program. Focuses on top management's
commitment as the key to a successful system. Personnel training,
preparation, field work and reporting are also considered basic
aspects of a regulatory auditing program.
Source: Environmental Analyst. April 1982, pp. 12-16. Mr. Cutler is
Manager, Regulatory Audits, Olin Corporation, 120 Long Ridge Rd.,
Stamford, CT 06904.
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8. ENVIRONMENTAL IMPAIRMENT LIABILITY. RISK ASSESSMENT. & PROPERTY TRANSFER
Title: "Environmental Audits in Connection with Property Purchases and
Sales"
Authors: Richard N. Cogen and Mary Elizabeth Ford
Doc. Type: Conference paper
Abstract: Discusses use of pre-purchase environmental audits to help companies
make informed decisions about environmental risks posed by planned
acquisitions or divestitures. Suggests that audits can save
companies money by providing information relevant to decisions
beyond the basic decision to buy or sell. Concludes that
pre-purchase audits are a beneficial resource that all companies
should consider when purchasing or selling property.
Source: The authors are with Nixon, Hargrave, Devans, and Doyle, PO Box
1051, Lincoln First Tower, Rochester, NY 14603. Presented at the
78th Annual Meeting of the Air Pollution Control Association, June
18, 1985.
Title: "Environmental, Health, and Safety Concerns in Acquisition Review"
Author: Jonathan Plaut
Doc. Type: Journal article
Abstract: Identifies three major concerns requiring consideration in any
acquisition activity: (1) substantial hidden defects or problems
(e.g. buried hazardous waste or emerging employee health problems),
(2) environmental, health, or safety problems requiring significant
capital expenditure, (3) overlooked latent opportunities revealing
significant additional financial advantages to the buyer. Briefly
discusses how acquisition teams should include these considerations
in the audit of company being acquired.
Source: Toxic Substances Journal. Vol.2, No. 3, Winter 1980-81, pp. 243-250.
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Title: "Evaluation of Environmental Accident Risk Assessments in New
Jersey"
Authors: John R. Renella, Harold Christiff, and Ramesh Kalagnanam
Doc. Type: Conference paper
Abstract: Reviews the N.J. Department of Environmental Protection's shift in
policy regarding accidental releases of air contaminants. Discusses
the "Environmental Accident Risk Assessments" conducted by two major
chemical companies at the request of the DEP- The EARAs included a
chemical screening analysis, detailed environmental accident
assessment, and a remedial action plan. Results indicated numerous
deficiencies at both facilities.
Source: New Jersey Department of Environmental Protection, 383 West State
St., Trenton, NJ 08618. Presented at the Annual Meeting of the
American Institute of Chemical Engineers, August 24-27, 1986,
Boston, MA.
Title: "Ways to Avoid Liability when Purchasing Property"
Author: Raymond W. Kane
Doc. Type: Book chapter
Abstract: Suggests that an environmental audit can be an effective mechanism
to identify potential liabilities during property transactions.
Describes six key steps in conducting an environmental audit:
review of Federal, state, and local regulatory requirements; review
of records and documentation related to environmental issues, for
information on compliance with regulations; interviews with key
staff; onsite physical inspection; risk evaluation; and reporting
the audit findings. Provides examples for each step, such as types
of regulations and ordinances to review, and suggests specific
areas, procedures, and equipment to inspect for audits of various
types of facilities.
Source: Impact of Environmental Law on Real Estate Transactions. Steven A.
Tasher (Ed.), Government Institutes Inc., 966 Hungerford Drive, #24,
Rockville, MD 20850. October 1986, pp 180-191
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Title: "A Systems Approach to Contingency Planning for Incidents Involving
Hazardous Waste Materials"
Authors: Jacqueline Shields, Richard C. Allison, Gary D. Holtzclaw, and Kirk
C. Harlow.
Doc. Type: Conference paper
Abstract: Develops the use of a systems approach to developing contingency
plans for hazardous waste releases and events. Using environmental
audits, companies can identify areas with the greatest potential for
uncontrolled events and can prioritize contingency planning efforts.
Source: Dr. Shields is with the Environmental Management Program, School of
Business and Public Administration, University of Houston-Clear
Lake, Box 317, 2700 Bay Area Blvd. Houston, TX 77058. Presented at
HAZPRO, April 1986, Baltimore, MD.
Title: "New Perspectives on Corporate Risk and Ways to Reduce It"
Author: Michael M. Gibson and Paul D. Fahrenthold
Doc, Type: Journal articles
Abstract: Part I: Suggests that corporate environmental affairs will change
from being reactive to anticipatory in the relationship between
corporate production and environmental activities. One need for
this anticipatory approach arises from "toxic tort" cases where
liabilities may exceed the net worth of the company.
Part II: Discusses attorneys' role in private-sector environmental
audits in the context of information gathering and confidentiality.
Explores competing demands an attorney may be subject to as
corporate counsel involved with auditing. Suggests how attorneys
should conduct themselves relating to ethics, who their clients are,
how to exercise independent judgment, how to protect confidences and
secrets, and what may occur when criminal conduct is found.
Source: The Environmental Forum. Vol.1, No.11, March 1983, pp. 35-41; Vol.
1, No. 12, April 1983, pp. 37-44.
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Title: "Environmental Impairment Liability Insurance and Risk Assessment"
Author: Paul MiIvy
Doc. Type: Journal article
Abstract: Briefly discusses the insurance industry's initial attempts to
insure against pollution episodes and focuses on environmental
impairment liability (EIL) insurance. EIL covers costs arising from
non-sudden events, a type of coverage which was not previously
available. Notes two main risks to be evaluated by underwriters in
offering an appropriate policy: (1) the risk to the environment and
public health and (2) the legal risks associated with a pollution
incident.
Source: The Environmental Forum. Vol.1, No.6, October 1982, pp. 30-37.
Title: "Environmental Risk Assessments and Environmental Audits"
i-.
Author: Richard S. Golob, Executive Editor
Doc. Type: Periodical article
Abstract: Presents an overview of insurance requirements and policy options
for firms mandated to carry insurance to meet RCRA regulations.
Includes summaries of insurance policies covering non-sudden
pollution and profiles of environmental auditing and risk assessment
firms.
Source: Hazardous Materials Intelligence Report. August 20, 1982, pp. 1-8.
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F. FEDERAL. STATS. AND LOCAL PERSPECTIVES AND ACTIVITIES
Title: "Environmental Auditing Policy Statement"
Author: U.S. Environmental Protection Agency
Doc. Type: Federal Register notice
Abstract: EPA's final policy statement on environmental auditing encourages
the use of auditing by regulated entities. Specifically encourages
development and implementation of auditing programs in industry, and
of initiatives of local governments. Discusses when the Agency may
request audit reports and explains how EPA's enforcement activities
may respond to industrial auditing efforts.
Source: Federal Register Vol. 51, No. 131, Wednesday, July 9, 1986, pp.
25004-25010.
Title: "Federal Government Initiatives in Environmental Auditing"
Author: Leonard Fleckenstein
Doc. Type: Conference paper
Abstract: Reviews recent Federal activities to advance the practice of
environmental auditing, including audit policy development and
implementation at EPA; audit program developments; availability of
audit protocols; audit-related regulatory and program
recommendations of the GAO; EPA guidance on audit provisions in
consent decrees; and a 1984 conference on environmental auditing for
Federal agencies.
Source: The author is with the Regulatory Innovations Staff, PM-223, U.S.
EPA, 401 N Street SW, Washington, DC 10460. Presented at the Annual
Meeting of the American Institute of Chemical Engineers, August 24-
27, 1986, Boston, MA.
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Title:
Author:
Doc. Type:
Abstract:
Source:
"A Review of Environmental Auditing Activities in Federal Agencies"
Engineering-Science and Policy Planning & Evaluation Inc., for U.S.
Environmental Protection Agency
Report (February 1987)
Reviews the status of environmental auditing activities of Federal
agencies, and reports on emerging trends. For each existing Federal
environmental auditing program, information is presented on:
program status (comprehensive, partial, under development); the
number of facilities audited; frequency with which the facilities
are audited; whether or not a formal protocol for auditing is used
during the audits; scope of the audits (which environmental
regulations or impacts the audit covers); and the source of auditing
personnel (internal agency staff, contractor staff, etc).
U.S. EPA, Office of Federal Activities, Office of
401 M St. S.W., Washington, D.C. 20460
External Affairs,
Title: An Introduction to Environmental Auditing
Author: Environmental Law Institute for Michigan Department of Natural
Resources (DNR)
Doc. Type: Booklet (1985)
Abstract: Summarizes reasons for undertaking audits and DNR's interest in
auditing. Discusses alternative audit approaches, key elements of
effective programs, how audits can be performed, and relevant
recordkeeping and disclosure issues.
Source: Local Assistance Section, Community Assistance Division, Michigan
Department of Natural Resources, Box 30028, Lansing, MI 48909.
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Title: A Handbook of Environmental
North Carolina
Auditing Practices and Perspectives in
Author: Martin A. Smith
Doc. Type: Report (1985)
Abstract: Provides a brief description and history of environmental auditing
and presents perspectives toward auditing of industry, the
environmental community, environmental lawyers and local governments
in North Carolina. Outlines four organizations' auditing systems,
lists reference materials, and discusses important considerations in
undertaking an auditing program, especially its potential for
pollution prevention and hazardous waste minimization.
Source: North Carolina Department of Natural Resources and Community
Development, Pollution Prevention Pays Program, P.O. Box 27687,
Raleigh, N.C. 27611.
Title: "BPA's Environmental Auditing Outlook: The Compliance and
Enforcement Office View"
Author: James R. Edward
Doc. Type: Conference paper
Abstract: Discusses the evolving role of EPA's Office of Enforcement and
Compliance Monitoring in environmental auditing, the critical need
for corporate facilities to meet their environmental
responsibilities, and the importance of self-monitoring and
reporting by companies. Also presents a brief history and status
update of EPA's recent activities involving Environmental Auditing,
and concludes with some perspectives on possible future directions
EPA's policy toward auditing may lead.
Source: Office of Enforcement and Compliance Monitoring, EPA, 401 M Street
SW, Washington, DC 2046Q. Presented at the Environmental Auditing
Workshop for Electric Utilities, September 27, 1984, Duluth, MN.
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Title:
Author:
Doc. Type:
Abstract:
Source:
"Environmental Auditing: Opportunities
Agencies"
and Implications for State
A. D. Little, Inc., Center for Environmental Assurance
Meeting/Workshop Notes (July 1984)
Summarizes an A.D. Little-hosted discussion of environmental
auditing among interested states. Highlights the topics discussed
and key points raised during the meeting, which focused on potential
public sector applications of and policies toward environmental
auditing.
A.D. Little, Inc., Center
Park, Cambridge, MA 02140.
for Environmental Assurance, 15 Acorn
Title: "Opportunities for Promotion of Environmental Auditing Through
State-Level Initiative: Observations and Recommendations Drawn .From
Other States"
Author: Richard N. Andrews and Martin A. Smith
Doc. Type: University paper (1983)
Abstract: Examines environmental auditing using information gained through
reports, journal articles, an informal survey of all states, and
conversations with state and industry representatives. Suggests
alternate methods for promoting environmental auditing at the state
level through legislation, administrative actions, enforcement
programs, technical support and numerous private-sector efforts.
Identifies methods for promoting environmental auditing among state
industries and public-sector entities, and discusses what steps will
be taken to institutionalize the state's auditing initiative.
Source: Institute for Environmental Studies, University of North Carolina,
311 Pittsboro Street 256H, Chapel Hill, North Carolina 27514.
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