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
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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.
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ANNOTATED BIBLIOGRAPHY ON ENVIRONMENTAL AUDITING
This bibliography is meant to be a reference for individuals interested in
environmental auditing, i.e., internal management systems for reviewing facility
operations and practices to assess and verify compliance with environmental
regulations and corporate policies. Environmental auditing, as an internal
management tool, offers significant potential benefits for the environment, for
industry, and for state and Federal agencies. It can better promote reduction in
emissions, effluents, and solid wastes; assure corporate management that its
facilities are in compliance with environmental requirements; and identify areas
of potential cost savings while reducing strains on governmental enforcement
programs. EPA has endorsed the concept of environmental auditing and is
committed to encouraging its expanded use.
This bibliography categorizes entries by subject area, based on each
publication's major area of emphasis. Many publications cover several subject
areas, but each publication is listed only once in this bibliography. The
subject areas are:
A. General Literature on Environmental Auditing
B. Audit System Design and Methodology
C. Confidentiality, Disclosure, and Other Legal Issues
D. Industry Experience and Perspectives
E. 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
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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
Hedstrom, 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
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Margo1is, Joshua D. A-7
Nays, Richard C-4
MiIvy, Paul E-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
Rene1la, 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
Samela, 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
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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-ll
Williams, John K. D-4
Young, R. Victor D-3
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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: All About Environmental Auditing
Authors: Ridgway M. Hall, Jr. and Oavid R. Case
Doc. Type: Book (1987)
Abstract: Describes the role of environmental audits in preventing violations,
in assisting management to comply with regulations, and in ensuring
compliance during growth and expansion. Presents an overview of
environmental laws and regulations and their applicability to onsite
operations. Outlines the procedures for planning and conducting an
environmental audit, and for analyzing and using the results.
Appendices include a questionnaire and sample inspection checklists
for determining compliance with various environmental laws, such as
RCRA, TSCA, Clean Air Act, and Clean Water Act.
Source: Federal Publications Inc., 1120 Twentieth St. N.W., Washington,
D.C. 20036
Title: Environmental Auditing Handbook
Author: Lee Harrison, Editor
Doc. Type: Book (1984)
Abstract: Details corporate environmental risks arising from major
environmental laws and how environmental auditing can reduce those
risks. Includes a section describing the undertaking of an audit.
Disclosure and confidentiality issues concerning the information
generated by an auditing program are discussed. Explores these
areas from the perspectives of: industry executives, auditors,
engineers, insurance brokers, and federal regulators.
Source: McGraw-Hill Book Company, 64 Wooster Street, 2W, New York, NY
10012.
A-2
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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 multidisciplinary in approach. Its thesis is that
through environmental auditing, businesses can anticipate and manage
pollution control problems and related environmental concerns,
rather than being forced to react to crises as they occur. A typical
issue will examine legal, scientific, and economic problems and
solutions, and raise environmental issues for further analysis.
Source: Published by Springer International, Springer-Verlag New York, Inc.,
175 Fifth Avenue, New York, New York 10010. More information may be
obtained from Robert S. DeSanto, Editor-in-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-3
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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-4
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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-5
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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-6
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Title:
/ thors:
Dof Type:
Al tract:
Source:
"Environmental Audit Program Development."
Joshua D. Nargolis, Dennis E. Strutz, and Richard S. Krouse
Conference paper
overview and brief history
of
.».
environmental auditing.
Presents
Provides questions about a company's current environmental
management program to use in determining the need for environmental
auditing. Discusses the different types and scopes of an EA
program, the advantages and disadvantages, and the issues that can
be addressed. Reviews procedures for staffing and organization.
Mr. Margolis is with 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
Do; Type: University dissertation
A street: 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, NC,
1985.
A-7
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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 of experts in the field of
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.
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-8
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Title: Conservation Exchange
Author: National Wildlife Federation
Doc. Type: Newsletter
Abstract: Several articles in the newsletter's Fall 1987 issue addressed
different aspects of environmental auditing. Among aspects
discussed are: the institutionalization of environmental auditing
within industries; formation of environmental auditing
organizations; reasons for popularity; benefits; and the lack of
national certification standards for environmental auditors.
Recommends industry efforts to establish uniform educational and
professional standards for the field. Speculates that federal
legislation mandating environmental auditing for regulated entities
is not likely in the near future. Discusses the efforts of a few
states to use legislative leverage to encourage environmental
auditing.
Source: Conservation Exchange. Vol. 5, No. 1, Fall 1987. Published by the
National Wildlife Federation, 1412 Sixteenth St. N.W., Washington,
D.C. 20036
Title: "Environmental Auditing: A Review of Current Practice"
Author: John W. Reed
Doc. Type: University thesis
Abstract: Describes environmental auditing and its roles and objectives in
industry, drawing comparisons between EA and financial auditing.
Defines the characteristics of audits with particular emphasis on
management structure within the company conducting audits. Benefits
of audits are seen to be an increased awareness of environmental
regulations which would culminate in increased environmental
protection. Disadvantages are seen primarily to be the newness of
EA, and the misunderstanding of ideas. Identifies disclosure and
confidentiality as issues that may be a disincentive to auditing.
Source: Submitted to York University, March 1984. Resource Center, Faculty
of Environmental Studies, York University, 333 Lumbers Building,
North York, Ontario M3J 1P3. Also available from Publications,
Conservation and Protection, Environment Canada, Ottawa Ontario K1A
OE7 (Pub. Ref. # IP-17). Mr. Reed is with Texaco, Canada Inc., 1210
Sheppard Ave. East, Willowdale, Ontario M2K 2S8.
A-9
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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, No.11, 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-10
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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-ll
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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-12
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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-13
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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
TRC Environmental Consultants, Inc.
Environmental Auditing Task Force.
Manual (1986)
for Edison Electric Institute,
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.
Assessment and Management Program (ECAMP);
Title: Environmental Compliance
Guidance Manual
Author: U.S. Air Force
Doc. Type: Manual (1986)
Abstract: 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.
Source: 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: Multi-Media Compliance Audit Procedures
Author: EPA National Enforcement Investigations Center
Doc. Type: Manual (June 1987)
Abstract: Details the procedures used by EPA or state inspectors authorized to
conduct multi-media compliance inspections of facilities. The
approach is intended to more effectively schedule the time of
investigatory personnel and support a rational system for analyzing
the compliance status of particular sources. Discusses the roles
and responsibilities of inspectors.
Source: U.S. EPA, National Enforcement Investigations Center, Federal
Center, Bldg. 53, Box 25227, Denver, Colorado 80225. EPA Report No.
EPA-330/9-87-001-R
B-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.
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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.] 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/EH-0053
B-5
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Title:
Author:
Doc. Type:
Abstract:
"An Approach to ES & H Assurance Programs for Institutions"
Source:
Sandia National Laboratories, Andrew
Jr., editors
Report (September 1982)
Ellingson and Charles Trauth,
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.
Prepared by Sandia National Laboratories, Albuquerque, New Mexico
87.185. 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 #ANL/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.
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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.
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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 ways 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.
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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.
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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.
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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.
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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.
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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
capi tal 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
OSHA. Describes training and use of non-environmental
professionals. Includes auditor's checklist.
Source: The authors are with Kraft, Inc., Kraft Court, Glenview, IL 60025.
Presented at the 58th Annual Conference of the Water Pollution
Control Federation, October 6-10, 1985, Kansas City, Missouri.
Title: "Environmental Auditing - A Management Tool"
Author: Patrick Atkins and Robert F. 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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B. ENVIRONMENTAL IMPAIRMENT LIABILITY. RISK ASSESSMENT. & PROPERTY TRANSFER
Title: "Environmental Audits in Connection with Property Purchases and
Sales"
Authors: Richard M. Cogen and Mary Elizabeth Ford
Doc. Type: Conference paper
Abstract: Discusses use of pre-purchase environmental audits to help companies
make informed decisions about environmental risks posed by planned
acquisitions or divestitures. Suggests that audits can save
companies money by providing information relevant to decisions
beyond the basic decision to buy or sell. Concludes that
pre-purchase audits are a beneficial resource that all companies
should consider when purchasing or selling property.
Source: The authors are with Nixon, Hargrave, Devans, and Doyle, PO Box
1051, Lincoln First Tower, Rochester, NY 14603. Presented at the
78th Annual Meeting of the Air Pollution Control Association, June
18, 1985.
Title: "Environmental, Health, and Safety Concerns in Acquisition 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. Rene1la, 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:
Author:
Doc. Type:
Abstract:
Source:
"New Perspectives on Corporate Risk and Ways to Reduce It"
Michael M. Gibson and Paul D. Fahrenthold
Journal articles
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.
The Environmental Forum. Vol.1, No.11, March
1, No. 12, April 1983, pp. 37-44.
1983, pp. 35-41; Vol.
E-3
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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"
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.
E-4
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F. FEDERAL. STATE. 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 M Street SW, Washington, DC 10460. Presented at the Annual
Meeting of the American Institute of Chemical Engineers, August 24-
27, 1986, Boston, MA.
F-l
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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 N 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: "EPA'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 20460. Presented at the Environmental Auditing
Workshop for Electric Utilities, September 27, 1984, Duluth, MM.
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Title: "Environmental Auditing: Opportunities and Implications for State
Agencies"
Author: A. D. Little, Inc., Center for Environmental Assurance
Doc. Type: Meeting/Workshop Notes (July 1984)
Abstract: 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.
Source: A.D. Little, Inc., Center for Environmental Assurance, 15 Acorn
Park, Cambridge, MA 02140.
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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