ENVIRONMENTAL AUDITING BIBLIOGRAPHY


(By Issue Category)
Compiled for:

Leonard Fleckenstein
Environmental Auditing Project Manager
Regulatory Reform Staff
U.S. Environmental Protection Agency
Washington O.C.
By:

Donna Downing
Program Analyst
The Skylonda Group
3000 Sand Hill Road
Menlo Park, California  94025

(415) 854-0723
February 1984

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                                                      28114
                     TABLE OF CONTENTS
General Articles on Environmental
   Auditing                                   1

Benefits of Environmental Auditing            4

Environmental Auditing Tools and
   Techniques                                 5

Issues in Confidentiality and
   Disclosure                                 8

State and Industry Experiences
   With Environmental Auditing                9

Environmental Auditing Experiences
   Abroad                                    12

EPA Perspectives on Environmental
   Auditing                                  13

EPA Speeches on Environmental
   Auditing                                  14

Issues Related to Environmental
   Auditing                                  16

Environmental Auditing Conference
   Proceedings                               20

Issues in  (Non-Environmental)
   Auditing                                  20

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BIBLIOGRAPHY OF ENVIRONMENTAL AUDITING MATERIALS
February 1984
GENERAL ARTICLES
American Management Systems, Inc., “Environmental Audit Model ”
(Prepared for U.S. EPA under contract No. 68—01—6636,
December 6, 1982)
Arthur D. Little, Inc., “Auditing——A New Entry on the Environmental
Balance Sheet ”
(Public Policy Notes, Vol. II, Sept. 1981.)
Arthur D. Little, Inc., “Environmental Auditing: An Overview ”
(Presented at Seminar on Private—Sector Environmental
Auditing, Washington, D.C., February 1983)
Business Week, “The Exploding Market for Environmental Audits ”
(Business Week, June 6, 1983, pp. 92b——92h)
Calder, “Perceptions of Environmental Auditing: A Marketing Research
Analysis ”
(Prepared on the basis of focus groups conducted June 1983,
for the EPA Regulatory Reform Staff)
Cutler, “Environmental Auditing: The Keystone to A Management
Compliance, Control, and Risk Assessment Program ”
(Environmental Analyst, April 1982, pp. 12—16.)
Deland, “Environmental Auditing ”
(Environmental Technology, Vol. 16, No. 9, 192, 1982.)
Drucker, “Environmental Auditing: An Ounce of Prevention ”
(Research Paper, Columbia University, May 1982)

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Environmental Law Reporter, “EPA Considers Environmental Auditing as
Enforcement Tool in Consent Decree ”
(Environmental Law Reporter, April 23, 1982, pp. 1711—12)
Greeno, “Scope of Environmental Auditing in the Private Sector ”
(Speech delivered at the Opinion Leaders’ Workshop, Alexandria
VA, June 9, 1983)
Hall, “A Noncompliance Penalty/Environmental Audit Approach to
Enforcement of Federal Water Pollution Regulations ”
(Masters Research Paper, University of Texas at Austin, 1982)
Hall & Case, “The Environmental Audit ”
(Washingtcn, D.C.: Federal Publications, October 1982;
course manual)
Hazardous Waste Report, “Environmental Audits ”
(Hazardous Waste Report, Vol. 4, No. 7, NOV. 1, 1982, pp. 5—8)
Hughes, Richie & Dul, “Overview of Environmental Compliance Auditing ”
(EEl Fifth Annual Conference on Environmental Licensing and
Regulatory Requirements Affecting the Electric Utility Industry,
Washington, D.C., October 1982)
Journal of The Air Pollution Control Association, “Corporate
Environmental Auditing Called Esential Tool in Ensuring Compliance
with Standards ”
(Journal of the Air Pollution Control Association, Vol. 32,
No. 5, May 1982, p. 540.)
Karlin, “The Environmental Self—Audit ”
(presented at ADL..’s Environmental Auditing Forum, February
25—26, 1981, oston, MA)
Kennedy, “The Need for Environmental Audits ”
(Pollution Engineering, July 1982, Pp. 28—30.)

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Kushnir & Kastury, “How to Self—Police for Regulatory Compliance ”
(Management Review, July 1982, pp. 47—51)
Linder & McBride, “Enforcement Costs and Regulatory Reform: the
Agency and Firm Response ”
(Center for Public Policy Studies, Tulane University,
New Orleans, LA, no date available)
Maclntyre, “Environmental Auditing: A Timely and Effective Tool ”
(Journal of the Air Pollution Control Association, Vol. 33,
No. 9, September 1983, pp. 909—913.)
Maclntyre, “The Role of Environmental Auditing for Industry and
Regulators ”
(Delivered at the APCA Annual Conference, June 1983)
N.Y. Times, “Big Business’s Pollution Problems Spawn a New Breed of
Auditors ”
(New York Times, Business Section, May 17, 1981, pp. F8—9)
Pairnisano, “The Evolution of Environmental Auditing: Implications for
Firms and Regulators ”
(Presented at the 76th Annual Meeting of the Air Pollution
Control Association, Atlanta, GA, June 1983)
Palmisano & Weiss, “Environmental Auditing: What Is It? ”
(Environmental Analyst, Vol. 4, No. 11, Nov. 1982, pp. 13—17.)
Penna, “Environmental Auditing: The Policy and Prospects ”
(The Environmental Forum, Vol. 2, No. 1, May 1983, pp. 16—20)
Radia & Kunes, “The Environmental Audit: Combining Cost Control With
Regulatory Compliance ”
(Modern Casting, February 1982, pp. 48—51)

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Reed, Environmental Auditing ”
(Air and Water Pollution Control Law: 1981, published by
The Environmental Law Institute, Washington, D.C.)
ROSS, Environmental Auditing: Self—Help that Hel _ ps the Environment ”
(Paper presented at Triangle Conference on Environmental Tech-
nology, Chapel Hill, N.C., April 7, 1983.)
Smith, “Environmental Auditing Policy: An Exploratory Analysis from
the Corporate Perspective ”
(Institute for Environmental Studies, University of North
Carolina, June 1983.)
Smith, “A Contingency view of Corporate Environmental Auditing and
Implications fcr Public Poli cy’ t
(Dissertation proposal at University of North Carolina
at Chapel Hill’s Dept. of Environmental Sciences and
Engineering, October 1983)
Truitt, et. al., “Environmental Compliance Auditing ”
(Environmental Regulation Analyst, July 1981, p. 2)
Watson, “Environmental Auditing Regulatory Concerns ”
(The Energy Bureau, Inc., Environmental Auditing Conference,
Washington, D.C, October 1982)
M. Weiss, “Environmental Auditing and Related Compliance Management
Systems Bibliography ”
(Prepared for EPA Regulatory Reform Staff under contract
No. 68—01—6636)
BENEFITS OF ENVIRONMENTAL AUDITING
Arthur D. Little, Inc., “Benefits to Industry of Environmental Auditing ”
(RRS/EPA report under contract No. EPA—230—08-83—005.) August,
1983.

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Chemecology, “Review Programs Help Companies Meet Environmental
Obligations ”
(Chemecology, July—August 1982, pp. 12)
Chemical Week, “Environmental Audits Cut Compliance Risks ”
(Chemical Week, May 28, 1980, pp. 72—3)
Clark, “Environmental Auditing Programs: Benefits to the Environment
and Government ”
(Report for RRS/EPA, prepared under contract No. 68—01—6636,
June, 1983)
Environment Reporter, “Companies’ Internal Auditing Systems Help
EPA Assure Corn liance, Official Says ” -
(Bureau of National Affairs, June 24, 1983)
Funkhouser & Greeno, “Why Conduct an Environmental Auditing Pr gram? ”
(Draft forthcoming in: “Environmental Auditing Handbook,
to be published by McGraw Hill)
ENVIRONMENTAL AUDITING TOOLS AND TECHNIQUES
Arthur D. Little, Inc., “Audit Tools and Techniques ”
(presented at Erie County, PA, conference “Environmental
Auditing and the Smaller Company” October 13, 1983)
Arthur D. Little, Inc., “Environmental Auditing Workbook ”
(Prepared by ADL for the Edison Electric Institute’s Environ-
mental Auditing Educational Task Force, 1983)
Arthur D. Little, Inc., “Sample Environmental Audit ”
(Prepared for the Environmental Auditing Roundtable, April 1983)
Arthur D. Little, Inc., “staffing and Organizational Issues in
Environmental Auditin g

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(Presented at the Erie County, PA, conference “Environmental
Auditing and the Smaller Company”, October 1983)
Baumer, “Making Environmental Audits t
(Chemical Engineering, Vol. 89, No. 22, November 1, 1982,
pp. 101—04)
Cahill, “Creating an Environmental Auditing Program ”
(The Energy Bureau, Inc., Environmental Auditing Conference
in Washington, D.C., October 1982)
Cutler, “Independence and Proficiency: The Essential Elements of an
Effective Environmental Auditing Program ”
(Chemical Manufacturers Association Conference on Environmental
Auditing, Washington D.C., September 27—28, 1983)
Frick, “Conducting an Environmental Audit ”
(Government Institutes Compliance Audit Seminar, October
1981, Section II)
Frick, Bouley & Cheever, “Analyzing the Data and Preparing the Final
Report ”
(Government Institutes Compliance Audit Seminar, October
1981, Section V)
Frick, Bouley & Cheever, “Gathering the Information ”
(Government Institutes Compliance Audit Seminar, October
1981, Section IV)
Frick & Cheever, “Structure of the Environmental Audit ”
(Government Institutes Compliance Audit Seminar, October
1981, Section III)
Friedman, “Organizing and Managing Effective Corporate Environmental
Protection Programs ”
(Done in—house at Occidental Petroleum Corp., Summer 1983)

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Giannotti, “Environmental Audits and Inspections ”
(Delivered by Giannotti of Occidental Petroleum, at a
conference titled “Current Perspectives: A Case Study
in Environmental Regulation and Litigation,” Austin,
Texas, December 1983)
Greeno & Hedstrom, “Getting to the Common: Alternative Approaches
to Environmental Auditing ”
(Draft, forthcoming in “Environmental Auditing Handbook”, to
be published by McGraw—Hill)
Greeno & Hedstroin, “Sizing Up Your Audit Program ”
(Draft, forthcoming in “Environmental Auditing Handbook”, to
be published by McGraw—Hill)
Guida, “A Practical Look at Environmental Audits ”
(Journal of the Air Pollution Control Association, Vol. 32, No.
5, August 1982, pp. 568.)
Kane, “Designing a Good Corporate Program for Environmental Management
and Compliance ”
(The Environmental Forum, Vol. 1, No. 6, October 1982, pp.
18—27.)
Marcus & Nadel, “Can you Trust your Environmental Auditing Program? ”
(Prepared for EPA/RRS under contract No. 68—02—3169 (wA42)
by Batelle Memorial Institute)
Pizzi, “Environmental Liability: Assessing Corporate Risk Programs ”
(Houston Business Journal, 14 December 1981, pp. 4—7)
Truitt, et. al, “Environmental Audit Handbook ”
(New York: Executive Enterprises Publications Co., Inc.,
1983)

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ISSUES IN CONFIDENTIALITY AND DISCLOSURE
Ferguson, “Confidentiality and Disclosure in Environmental Auditing ”
(Prepared for EPA Regulatory Reform Staff under contract
NO. 68—01—6636. March 1983)
Gibson & Fahrenthold, “New Perspectives on Corporate Risks and Ways
To Reduce It,” Part II
(The Environmental Forum, Vol. 1, No. 12, April 1983, pp. 37—44)
Henz, “Safeguarding Confidential Business Information ”
(Presented at the 76th Annual APCA Meeting in Atlanta, GA,
June 1983, by PEDCO Environmental, Inc.)
OECD, “Confidentiality of Data and Chemical Control ”
(Paris, France, 1979)
Reed, “Environmental Audits and Confidentiality: Can What You Know
Hurt You As Much As What You Don’t Know? ”
(Environmental Law Reporter, 13 ELR 10303, October 1983)
Rosen, “Confidentiality and the Audit ”
(Presented at PP&L’s Environmental Auditing Workshop,
Allentown PA, January 27—28, 1982)
Weinberg, “Confidentiality and the Environmental Audit ”
(The Energy Bureau, Inc., Environmental Auditing Conference,
Washington, D.C. October 1982)
M. Weiss, “Issues of Confidentiality and Disclosure in Environmental
Auditing ”
(Prepared for EPA’S Regulatory Reform Staff under Contract
No. 68—01—6636)

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STATE AND INDUSTRY EXPERIENCES WITH ENVIRONMENTAL AUDITING
Andrews and Smith, “Opportunities for Promotion of Environmental
Auditing Through State—Level Initiative: Exploratory Activities in
North Carolina ”
(Institute for Environmental Studies, University of North
Carolina, 311 Pittsboro Street, 256H, Chapel Hill, N.C. 27514)
September 1983.
Andrews and Smith, “Opportunities for Promotion of Environmental
Auditing Through State—Level Initiative: Observations and Recommend-
ations Drawn from Other States ”
(Institute for Environmental Studies, University of North
Carolina, 311 Pittsboro Street, 256H, Chapel Hill, N.C. 27514)
August, 1983.
Arthur D. Little, Inc., “Environmental Audit Reporting: A Study of
Current Practices ”
(Presented at the Seminar on Private Sector Environmental
Auditing, Washington D.C., February 1983)
Arthur D. Little, Inc., “Issues in Environmental Auditing: Corporate
Practices and Future Trends ”
(Published by ADL’s Center for Environmental Assurance,
November 1981)
Arthur D. Little, Inc., “Profiles of Environmental Auditing Programs ”
(ADL Center for Environmental Assurance, 1980)
Arthur D. Little, Inc., “A Survey of Environmental Auditing ”
(ADL Center for Environmental Assurance, 1982. Presented at
Seminar on Private Sector Environmental Auditing, Washington,
D.C.)
Atlantic Richfield Company, “Atlantic Richfield Company Environmental
Review Program ”
(Los Angeles: Occupational and Environmental Protection
Council, 1980)

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Barzotti & Breeding, “General Motors Environmental Auditing Experience ”
(The Energy Bureaur Inc., Environmental Auditing Conference,
Washington, D.C., October 1982)
Basta, “A Utility’s Experience with An Environmental Quality Assessment
Program ”
(Presented at the 76th Annual Meeting of the Air Pollution
Control Association, Atlanta, GA) June, 1983.
Chemical Week, Decentralizing Environmental Burdens ”
(Chemical Week, March 3, 1982, pp. 37—38)
Edison Electric Institute, Survey on Environmental Auditing:
Results ”
(Conductei by EE l on members of the EEl Energy and
Environment Committee. Undated)
The Groundwater Newsletter, “Despite Reduced Federal _ Role, Companies
Feel Auditing Pressure ”
(The Groundwater Newsletter, Vol. 11, No. 1, January 17, 1982,
p. 1)
Harrison, “Environmental Audit Letter ”
(Monthly Environmental Auditing Newsletter. File includes
May 1983 to present)
Hazardous Materials Intelligence Report, “Environmental Risk Assessments
and Environmental Audits ”
(Hazardous Materials Intelligence Report, August 20, 1982, p.
1—8)
Hazardous Waste Management Bulletin, “Self-Auditing Program Monitors
Compliance ”
(Hazardous Waste and Pollution Management Bulletin, Vol. 1,
3303, February 10, 1983, p. 1—2.)
Hurd, “Environmental Audit Case Studies ”

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(Delivered at the Conference on Environmental Liability
Management, Arlington, VA, October 28—29, 1982)
Industry Week, “Environmental Audits Catch Industry’s Eye ”
(Industry Week, April 5, 1982, p. 29)
Jeronimus, “Environmental Audit: The Role in Corporate Compliance ”
(Presented at Minnesota Power’s Conference on March 8—9,
1983, in Bloomington, MN)
Kelly, “Environmental Audit Process at ARCO ”
(Delivered at the Conference on Environmental Liability
Management, Arlington VA, October 27—28, 1982)
Langfelder, “North Carolina Encourages Environmental Auditing ”
(Presented at the Environmental Auditing Opinion Leaders’
Workshop, Alexandria, VA, June 1983.)
Pennsylvania Power and Light Co., “Self—Auditing: A New Approach to
Environmental Regulation ”
(Public Issues and Perspectives, Vol. 2, No. 1. PP&L, Allentown,
Penn., undated.)
Pennsylvania Power & Light Co., “Pennsylvania Power and Light: The
Audit Process, Future Directions ”
(Delivered at PP&L’s Environmental Auditing Workshop, Allen-
town, PA, January 27—28, 1982)
Rademacher, “Environmental Management in the Velsicol Chemical Corpor—
ation ”
(Remarks made before the Executive Enterprises, Inc., course on
Environmental Auditing, Chicago, September 17—18, 1981)
Rayer, Environmental Surveillance: Allied Chemical Company’s Approach ”
(The Energy Bureau, Inc., Environmental Auditing Conference,
Washington, D.C., October 1982)

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Robinson, “EEl’s Environmental Auditing Task Force ”
(Presented at Edison Electric Institute Fifth Annual Conference
on Environmental Licensing and Regulatory Requirements Affecting
the Electrc Utility Industry, Washington D.C., October 27—2 l9Rfl
Ross, “Environmental Auditing and North Carolina: Regulators
Encourage Use of A Catalyst for Environmental Protection ”
(Presented at the 76th Annual Meeting of the Air Pollution
Control Association, Atlanta, Georgia, June, 1983)
Voss, “Environmental Regulation: Corporate Compliance Response in
the Chemical Industry ”
(Thesis presented to the School of Public Affairs, University
of Texas, Austin TX, August 1982.)
ENVIRONMENTAL AUDITING EXPERIENCES ABROAD
Badaracco, “A Study of the Adversarial and Cooperative Relationships
Between Businesses and Government in Four Countries ”
(Prepared for the Dept. of Commerce’s Office of Technology,
Stategy and Evaluation, February 3, 1981)
Gutmanis, “Report on Western European Environmental Audits ”
(Draft Report prepared for EPA Reggulatorty Reform Staff
under contract, July 1983)
Haddad, “French Report on Environmental Auditing ”
(Draft memo to John Palmisano, EPA/RRS, undated)
OECD, “Provisions for Environmental Assessment Procedures in OECD
Countries ”
(Paris, France: Secretariat Report, 1979)

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EPA PERSPECTIVES ON ENVIRONMENTAL AUDITING
B].umenfeld, “Year—End Environmental Auditing Report ”
(Report submitted to the Regulatory Reform Staff, EPA,
February, 1983.)
Blumenfeld & Haddad, “Beyond the Battleground: A (Non)Regulatory
Perspective on Environmental Auditing ”
(Report for the RRS/EPA, March, 1983.)
Inside EPA, “New Environmental Audit Plan: Staff Adds Flexibility,
Keeps Inspections ”
(Inside EPA, 12 February 1982, pp. 2—3)
Inside EPA, “Reçulatory Reform, Enforcement Staff Push Environmental
Auditing Approach ”
(Inside EPA, 4 September 1981, p. 1)
Inside EPA, “Staff Planning Push for Unique Enforcement Audits, Debates
Industry Role ”
(Inside EPA, 16 October 1981, p. 4—5)
Inside EPA, “Staff Supports Voluntary Environmental Auditing, Rejects
Mandatory Plan ”
(Inside EPA, 11 December 1981, p. 8)
Palmisano, “Environmental Auditing as Part of Compliance Reform ”
(Prepared for EPA Regulatory Reform Staff, January 1983)
Palmisano, “Environmental Auditing: What It Is and Why EPA Cares ”
(Prepared for EPA Regulatory Reform Staff)
Palrnisano, “Regulatory Perspectives on Environmental Auditing ”
(Presented at the American Institute of Chemical Engineers
1982 Summer National Meetings, Cleveland OH, September 1982)

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Russell, “Regulatory Reform at the New EPA ”
(Pollution Engineering, December 1983, p. 23—25)
M. Weiss, “Environmental Auditing: A Government Perspective:
New Directions? ”
(Delivered at a conference titled ‘Current Perspectives:
A Case Study in Environmental Regulation and Litigation’
hosted by the Texas Bar in Austin Texas, December 1983)
EPA SPEECHES ON ENVIRONMENTAL AUDITING
Blumenfeld, “Environmental Auditing: A Federal Perspective ”
(Slides presented at the Opinion Leaders’ Workshop,
Alexandria, Virginia, June, 1983.)
Blumenfeld, “Environmental Auditing Panel: Chicago Regulatory
Reform Conference ”
(Environmental Auditing Panel, Regulatory Reform
Conference, Chicago IL, April 29, 1982)
Riurnenfeld, “A Federal Regulatory Perspective on Environmental
Auditing ”
(Talking points for EEl’s meeting in New Orleans, LA,
on May 20, 1982)
Blumenfeld, “Remarks at the Environmental Liability Management
Conference ”
(Conference sponsored by the Center for Energy and Environ-
mental Management, Arlington VA, October 28, 1982)
Cannon, “Remarks to Allied Corporation Business Planning and Pollution
Meeting ”
(Speech delivered at the Allied Corp. Business Planning and
Pollution Control Meeting, Morristown, N.J., June 9, 1982)
Cannon, “Remarks to the American Bar Association Meeting ”

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(Presentation to the American Bar Association Annual
Meeting, San Francisco CA, August 11, 1982)
Cannon, “Remarks to the International Convocation for World Environ—
mental Regeneration ”
(International Convocation for World Environmental
Regeneration, New York City, February 24, 1983)
Cannon, “Remarks at the 0MB Interagency Workshop ”
COMB Interagency Workshop on Auditing and Self—Certification,
November 9, 1982)
Cannon, “Remarks at the Opinion Leaders’ Workshop ”
(Speech at the Environmental Auditing Opinion Leaders’
Workshop, Alexandria, VA, June 9, 1983.)
Cannon, “Trust Everyone——But Cut the Cards: Environmental Self—
Regulation and Corporate Responsiveness ”
(Speech before the Ethics Resource Center Conference on
Self—Regulation, Washington D.C., November 1982.)
Crampton, “Presentation to Utilities Air Regulatory Group: Environ-
mental Auditing ”
(Utilities Air Regulatory Group: Environmental Auditing;
April 13, 1982)
Fleckenstein, “Environmental Auditing: Prospective Policy Directions? ”
(Presented at the Annual Meeting of the Pacific Northwest
International Section, Air Pollution Control Association,
Seattle, WA, November 17, 1983)
Fleckensteirt, “EPA Efforts to Promote Environmental Auditi :
(Speech presented at the Chemical Manufacturers Association,
Seminar on Environmental Auditing, 9ouston, TX, September 27,
1983.
Fleckenstein, “Remarks to the Carolinas Air Pollution Control Asso—
ciat ion ”

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(Presented at The Carolinas Air Pollution Control Asso-
ciation, Myrtle Heach SC, October 27, 1983)
Levin, “Remarks at the Third Annual Environmental Permitting
Symposium ”
(American Institute of Mining, Metallurgical and Petroleum
Engineers——Colorado Section, Third Annual Environmental
Permitting Symposium, February 7, 1983)
ISSUES RELATING TO ENVIRONMENTAL AUDITING
Barain, et. al., “Managing Risks to Health, Safety and Environment by
the Use of A1t rnatives to Regulation ”
(New England Law Review, Vol. 16:4 (1981), p. 657—687)
Chester, “A Quality Assurance Management Plan ”
(Journal of the Air Pollution Control Association, Vol.
29, No. 7., July 1979, pp. 701—703.)
Clark, “Comments at Conference on Self—Regulation ”
(Comments at Conference on Self—Regulation, in
Washington D.C., November 16, 1982)
Collins, “Utility Environmental impairment Liability Insurance ”
(Presented at the Edison Electric Institute/Environsphere
Company Sixth Annual Conference on Environmental Licensing
and Regulatory Requirements Affecting the Electric Utility
Industry, November 1, 1983.)
CONSAD Research Corp., “Environmental Regulations and Small Business:
An Overview of Issues Concerning the Economic Impact of EPA Regulations
on Small Businesses ”
(Prepared for U.S. EPA under Contract No. 68—01—6543, Work
Assignment No. 49. October 25, 1983)

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Corn & Lees, “The Industrial Hygiene Audit: Purposes and Implementation ”
(American Industrial Hygiene Association Journal, Vol. 44,
February 1983, pp. 135—141.)
Freedman & Jaggi, “The SEC’s Pollution Disclosure Requirements:
Are They Meaningful? ”
(California Management Review, Vol. XXIV, No. 2, Winter, 1981,
pp. 60—67.)
Frost, “Toxic Tort and Pollution Liability ”
(The Energy Bureau, Inc., Environmental Auditing Conference,
Washington, D.C. October 1982)
Gibson & Fahrer thold, “New Perspectives on Corporate Risk and Ways
To Reduce It,” Part I
(The Environmental Forum, Vol 1, No. 11, March 1983, pp. 35—41)
Grumbly, “Corporate Disclosure and Third—Party Enforcement Under the
Securities and Exchange Commission: A Model for Environmental Auditing? ”
(Prepared for EPA Regulatory Reform Staff by Temple,
Barker & Sloane, Inc., under contract No. 68—01—6558,
April 1983)
Haas, “Industrial Hygiene Audits ”
(American Industrial Hygiene Association Journal, Vol. 43,
No. 8, August 1982, pp. 562—568.)
Hauser, “Quality Assurance Update ”
(Environmental Science and Technology, Vol. 13, No. 11,
NOV. 1979, pp. 1356—1361)
Karlin, “A Corporate Approach to Product Risk Assessment ”
(Presented at the conference sponsored by the Machinery
and Allied Products Institute Product Liability Council,
Washington, D.C., December 14—15, 1981)

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Ruby, et. al., “Assessment of Innovative Enforcement Procedures ”
(Acurex Draft final Report No. 79—24/EE, Prepared for
U.S. EPA under contract No. 68—01—4142, Task 20, October
1979)
Linder, “Self Certification and Regulatory Reform, ”
(Center for Public Policy Studies, Tulane University,
New Orleans, LA 70118)
Linder & McBride, “Self—Certification and Regulatory Reform: A
Design Framework ”
(Presented at the Fourth Annual Conference of the Association
for Public Policy Analysis and Management, Minneapolis, Minn.,
October 28, 1982)
Lynch, “Environmental Disclosure Obligations Under Federal Securities
Laws ”
(The Energy Bureau, Inc., Environmental Auditing Conference,
Washington, D.C., October 1982)
Marguglio, “Environmental Compliance and Universal Quality Assurance ”
(Quality Progress, Sept. 1981, p. 14—18; distributed at PP&L’s
Environmental Auditing Workshop, Allentown PA, Jan. 27—28, 1982)
Miller, “Law and Information Systems ”
(Journal of Systems Management, January 1977, pp. 22—29)
Milvy, “Environmental Impairment Liability Insurance and Risk Assessment ”
(The Environmental Forum, Vol. 1, No. 6, October 1982, pp. 30—37.)
Molitor, “Environmental Reforms and the Evolution of Regulatory
Innovations ”
(Presented at the Environmental Auditing Opinion Leaders’
Workshop, Alexandria, VA, June 9, 1983.)

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Nadel, “Assessments of Management Controls and Auditing by Selected
Organ izat jons ”
(Prepared by Battelle, Inc., for EPA Regulatory Reform Staff,
May 1983)
Sandia Corp., “An Approach to ES&R Assurance Progams for Institutions ”
(Sandia Report SAND82—l221, September 1982)
Shanoff, “Regulatory Inspections: Court Takes Case—By—Case Approach ”
(Solid Wastes Management, February 1980, p. 80)
Schreyer, “Microcomputers Provide Cost-Effective Environmental
Monitoring for Pollution Control ”
(Mini—Micro Systems, Vol. XV, No. 10, Oct. 1982, pp. 177—180)
Temple, Barker & Sloane, Inc., “The Relatlonship Between Environmental
Impairment Liability Insurance and Environmental Auditing ”
(Prepared for EPA Regulatory Reform Staff under contract
No. 68—01—6558, October 1982)
U.S. Environmental Protection Agency, Office of Enforcement, “Assess-
ment of Innovative Enforcement Procedures ”
(Contract No. 68—01—4142, Task 20. October 1979)
U.S. Environmental Protection Agency, Office of Enforcement, “An
Overview of Pilot Compliance Monitoring ”
(National Enforcement Investigations Center, Denver CO,
January 1978)
U.S. Environmental Protection Agency, Office of Legal and Enforcement
Counsel, “Multi—Media Compliance Audit Inspection Procedures ”
(Prepared by the National Enforcement Investigations Center,
Denver, Colorado, February 1983)
U.S. Environmental Protection Agency, Office of Toxic Substances,
“ Voluntary Environmental Activities of Lar ge Chemical Companies tO
Assess and Control Industrial Chemicals ”

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(Report No. 560/4—76—009. September 1976)
Weiss, “Social Regulation of Business Activity: Reforming the
Corporate Governance System to Resolve an Institutional impasse ”
(UCLA Law Review, Vol. 28, No. 3, February 1981)
Wilkenfeld, “Management Control of Environmental ProgramC
(The Diplanate of the American Academy of Environmental
Engineers, January 1981, pp. 5—6.)
ENVIRONMENTAL AUDITING CONFERENCE PROCEEDINGS
Arthur D. Little, Inc., Seminars on Private—Sector Environmental
Auditing (Proceedings) ”
(Conference sponsored by EPVs Regulatory Reform Staff,
February 15, 1983)
Chemical Manufacturers’ Association, “Environmental Auditing Seminar
Proceedings’ t
(CMA Conference on Environmental Auditing, Washington D.C.,
Septeuter 27—28, 1983)
Ethics Resource Center, Self—Regulation: Conference Proceedings ”
(Conference at Washington, D.C., November 16, 1982)
M. Weiss, “Environmental Auditing Opinion Leaders’ Workshop
Proceedings ”
(Report prepared by Malcolm Weiss under EPA Contract No.
68—01—6636, June 1983.)
ISSUES IN (NOti—EWIRONMENTAL) AUDITiNG
American institute of Certified Public Accountants, “operational
Audit Engagements ”

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(Report of the Special Committee on Operational and Management
Auditing. Available from the American Institute of Certified
Public Accountants, 1211 Avenue of the Americas, New York, N.Y.
10036) January, 1982.
Arthur D. Little, Inc., “Financial Accounting in the U.S.: Its
Development and Current Practice ”
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