ANNOTATED BIBLIOGRAPHY ON
ENVIRONMENTAL AUDITING
[Fourth Edition]
MARCH 1985
Refulatory Reform Staff
* Sf.ftand«d8 and Regulations
US lnv?™Cy> !lannin8' and Evaluation
U. S. Environmental Protection Agency
Washington DC 20460
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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 reductions
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 and Disclosure
D. Benefits of Environmental Auditing
E. Industry Experience and Perspectives
F. Environmental Impairment Liability/Risk Assessment
G. Federal, State and Local Perspectives and Activities
Each entry includes the author and type of document as well as a brief abstract
which capsulizes 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.
This bibliography does not include all published materials on environmental
auditing. There are many other articles, papers and reports on auditing than are
included here. Instead, this bibliography 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 Reform Staff (PM-223), U. S. Environmental
Protection Agency, 401 M Street, S.W., Washington, DC 20A60 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
Andrews, Richard N. G3
Argonne National Laboratories 8—2
Arthur D. Little, Inc. A—i, B—i, 1)-i,
E—i, E—2, G-2
Barisas, S., et al 8-2
Basta, Michael F. E-2
Blakeslee, H. William P,-3
Blunenfeld, Karen G—l
Cahill, Lawrence B. 8-2
Case, I vid R. A—2
Clark, iwin H., II 1)-i
Cutler, RDbert W. E—2, E- 3
Er3ward, James R G-2
Ellingson, Andrew 8-3
Environmental Law Institute C—2
EW Nati. Enforoement Investigations Ctr. 8-2
E 1 gulatory form Staff G-2
Fahrenthold, Paul D. F—i
Fleckenstein, 1 onard ci-i
Giannotti, t vidA. E-3
Gibson, Michael M. F—i
(blob, Richard S. F-i
Gratx3wski, Theodore 8-3
Greene, 1. Ladd, et al 8-1
Giida•, Joseph A- i
— ii—.
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Haddad, Mark 0-1
Hall, Ridgeway M,, Jr. A—2
Harrison, Lae A—i
Benz, rx)nald J. C—2
JRB Associates Inc. 0-3
Kane, Rayrtond w. A—4
Mactntyre, Stephen T. E—3
Marcus, Alfred A. B-3
Milvy, Paul F—i
t del, Mark V. B—3
Palmisano, John A—3
f nna, Richard A. A—3
Reed, John N.
Reed, Phillip D. C—i
Ross, William G. C—i
Sandia National Laboratories B—3
Simon, Michael A—4
Smith, C. Ronald 0—3
Smith, Martin A. E—4, G—3
Trauth, Charles, Jr. B—3
Truitt, ThQrtas H., et al 3—1
iss, Malcolm C. A—3, C—i
Wiliborn, Walter A—4
—iii—
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A. GENERAL LITERATURE ON ENVIRONMENTAL AUDITING
Title: Environmental Auditing Handbook
Auth,r: Lee Harrison, Editor
tkc. Type: Book (1984)
Abstract: Details corporate environmental risks arising fran major erwironnental
laws and how environmental auditing cart reduce those risks. Includes a
section describing the undertaking of an audit. Disclosure and conf i-
dentiality issues concerning the information generated by an auditing
program are discussed. cplores these areas fran the perspectives of:
industry executives, auditors, engineers, insurance brokers, and
federal regulators.
Source: M Graw-Hil1 Book Cctipany, Lee Harrison, Editor, 64 Wooster Street, 2W,
New York, NY 10012.
Title: “A Practical Lock at Environmental Audits”
Auth ,r: Joseph Guida
c. Type: Journal paper
Abstract: Discusses the rise of the audit trend and advantages gained by using
an auditing system. Different approaches available to corporations
instituting auditing programs are then broadly defined. The strategy
enpioyed by a particular firm is dependent upon the characteristics of
that firm and the type of data corporate officers desire.
Source: Journal of the Air Pollution Control Association , Vol. 32, No.5,
A igust 1982, pp. 568.
Title: “Environmental Auditing: An Overview”
Autbor: Arthur D. Little, Inc., Center for Environmental Assurance
fl c. Type: Report (1983)
Abstract: Describes the different f nct ions and objectives which private-sector
environmental auditing can serve. It develops an audit process des i ed
to create an audit report giving corporate managers reliable inforrna-
tion 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, Washington, D.C., February 15, 1983.
A-i
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Title: “Environmental Auditing: A Review of Current Practice”
Author: John W. Reed
DDe. Type: University thesis
Abstract: This document describes environmental auditing and its roles and objectives
in industry, drawing cc*1 iparisons between E and financial auditing.
The characteristics of audits are defined with particular emphasis on
management structure within the company conducting audits. Audit procedures
are described as well as benefits and disadvantages. Benefits 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 FA, and the misunderstanding of
ideas. Disclosure and confidentiality are also identified as issues
that may be a disincentive to auditing.
Source: Disertation sutxnitted to York University, March 1984.
Mr. Reed is at 2320 ( rrard Street East, Ibronto, c tario, Canada, M4E 251.
Title: “Environmental Auditing in the Canadian Private Sector”
Author: John W. Reed
DDc. Type: Report (t cember 1984)
Abstract: Provides an overview of the environmental auditing concept, addressing
its origins, uses, characteristics and current practice in Canadian
industry. Information was collected through a survey of 116 Canadian
companies in eleven major industrial sectors regarding their awareness,
use, and attitudes toward environmental auditing.
Source: Unpublished report of the Environmental Protection Service, Environment
Canada. Contact: Mr. A. Steizig, Industrial Programs Branch, Environmental
Protection Service, Environment Canada, Ottowa, (Y tario, Canada Kl 1C8.
Mr. Reed is at 2320 Gerrard Street East, Thronto, C tario, Canada, r43J 1L3.
Title: Environmental Auditing Course Manual
Author: Ridgeway M. Hall, Jr. and I vid R. Case
DDc. Type: Course Manual (1982)
Abstract: 1 eats environmental audits as manag ent tools helpful in identifying
liabilities, preventing violations and creating the data necessary to
respond to government requests for information. Chapters detail the
planning of art audit, the regulatory requirements, and legal means of
protecting confidential information. Concludes with a chapter describ-
ing how audit information can best be utilized.
Source: rowel1 & Moring, 1100 Connecticut Avenue, Suite 1200, Washington,
D.C., 20036, or F deral Publications, Inc., 1120 20th Street N.W.,
Washington, D.C., 20036.
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Title: “The Ec,olution of thviron:nental Auditing: Implications r Firms and
for Regulators”
Autbor: John Palmisano
Doe. Type: Conference paper
Abs tract: Distinguishes “environmental auditing” fran “ccxnpliance assurance,” and
discusses auditing as a management information system. Examples are
offered of lxw auditing systems might work and what benefits can be
expected. EPA’s policy on environmental auditing as a means for establishing
a n private sector/public-sector partnership is also discussed.
Source: Mr. Palmisano is with AERX Division, Residuals Management Technology,
1901 Pennsylvania Ave., N.W., Washington, DC 20006. Presented at the
76th Annual Maeting of the Air Pollution Control Association, Atlanta,
Georgia, June 1983.
Title: “Environmental Auditing: iat Is It?”
thr: John Palinisano and Malcolm C. iss
Doe. Type: Journal paper
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 outweigri 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 prc*tibitively high.
Scurce Environmental Analyst ; Vol.4, No.11, Ncwember 1983, pp. 13-17.
Mr. Palmisano and Mr. Weiss are with ff/AER*X Division, 1901 Pennsylvania
Ave., NW, Washington, D.C. 20006.
Title: “Environmental Auditing: The Policy and the Prospects”
AutFor: Richard A. Penna
Doe. Type: Journal paper
Abstract: Discusses probable goals and potential benefits of typical err riron-
mental auditing programs. It briefly traces the history and policy
evolution of auditing in both the public arid private sectors and
suggests sane of the major factors to be considered in desiguing an
auditing program. Concludes that auditing is one area in the environ-
mental arena where industry may assist in shaping the future.
Source: The Environmental Forum , Vol.2, No.1, May 1983, pp. 16-20.
A-3
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Title: ‘ t Desigting a Good Corporate Program for thvironmental Management
and Canpliance”
Auttnr: Baynorxl W. Kane
Doe. Type: Journal paper
Abstract: Contends that environmental responsibilities are too important to be left
to junior staff and operating personnel at the facility. Rather, corporate
headquarters and senior executives must begin taking abtive roles. Ten
elements of a corporate environmental management program are listed and
briefly discussed.
Source: The &wironmental Forwn , Vol.1, No.6, October 1982, pp. 18-27.
Mr. Kane is with Roy F. Weston Co., Weston Way, West Chester, PA 19380.
Title: “Operational Audit Engagements”
Auttor: Miltiple (Michael Sinon, Chairman)
Doe. Type: Article
Abstract: Describes “operational audits” as audits of the activities of an en-
térpri se exclusive of financial transactions and those of an extraor-
dinary character. Operational audits are distinct fran financial
audits, and can be performed by CPA firms as a new service to their
clients. The primary benefits fran operational audits include: (1)
identification of criteria for measuring achievement of organizational
objectives; (2) an independent, objective eialuation of specified
operations; and (3) assessment of effectiveness of management control
systems.
Source: American Institute of Certified Public Accountants, Report of the
Special Canmittee on Operational and Management Auditing, 1211 Avenue
of the Americas, New York, N.Y. 10036 (January 1982).
Title: “Canperxiitrn of Audit Standards”
Author: Walter Wil lbom
Doc. Type: Report (1983)
Abstract: Suninarizes existing audit standards and guidelines issued by: the
institute of Internal Auditors, the American institute of CPAs,
Canadian Standards Asociation, ANSIIAS€, Covennent of Canada, arxl
the U.S. General Accotnting Office.
bphas iz es can,nalit Las Wt€ these standards. Mdr esses general features
of audit standards and major audit issues such as: auditor requirements,
organization, audit planning and procedures, audit reports, audit
canpietion and quality assurance.
Source: American Society ftr Quality Control, 230 W. Wells Street, Milwaukee,
Wisconsin 53203.
A-4
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B. AUDIT SYSTEM DESIGN AND ? H0D0LflGY
Title: Environmental Auditing: Thindamentals arid Techniques
Author: J. Ladd Greeno, Gilbert S. Redstran, and Maryanne DiBerto
well as the techniques of
practical guides to audit program
appendices with audit protocols
pollution and solid and hazardous
Source: John Wiley & Sons, 605 Third Avenue, New York, NY 10158.
The authors are with the Center for Environmental Asssurance, Arthur D.
Little, Inc., 15 Acorn Park, Cambridge, ?Ik 02140.
Title: Environmental Audit Handbook: Basic Principles of Environmental Ccmpliance
Auditing .
Author: Thcxnas H. Truitt, et al
Doe. Type: Book (1983)
Comprthensively addresses the managerial, legal and procedural elements
necessary to produce a quality environmental audit. The audit is charac-
terized as a way to measure a plant’s compliance performance against regu-
latory standards. Includes a lengthy section on planning and conducting
audits as well as evaluating the data generated. Legal issues arising
fran potential disclosure of audit information under SEC and major
federal environmental regulations are addressed.
Source: Executive Enterprises Publications Co., Inc., 33 West 60th Street,
New York, NY, 10023.
Mr. Truitt is with Wald, Harkrader & Ross, 1300 Nineteenth Street, N.W.,
Washington, D.C., 20036
Title: Environmental Auditing Workbook
Author: Arthur D. Little, Inc. for the Edison Electric Institute
Doe. Type: Book (1983)
Provides electric utility management and staff with the information and
background necessary to decide thether enviror3nental auditing makes sense
for their organizations. Contains examples and alternate approaches
for those interested in implementing an environmental auditing system;
provides analyses of basic design issues and techniques for conducting
environmental audits; and serves as a guide for the manager charged with
administering the audit program.
Source: Edison Electric Institute, Environmental Auditing Task Force,
1111 Nineteenth Street, LW., Washington, D.C., 20036
Doc. Type: Book (1985)
Abstract:
Addresses the emerging principles as
environmental auditing, and provides
design arid implementation. Includes
and questionnaires for air and water
waste management.
Abstract:
Abstract:
B-i
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Title: Environmental Audits
Author: Lawrence B. Cahill, Editor
Dcc. Type: Book (October 1983)
Abstract: Historical background and description of environmental auditing pro-
grams, with emphasis on EPA’ s perspective and on the actual perform-
ance of an audit itself. Sample qi stionairès arx I audit checklists
are provided as an example of the procedures and methods to follow.
Source: Government Institutes, Inc., 966 Hungerford Drive, #24, Rockville,
MD, 20850.
Title: Internal Environmental Protection Audits: A Suggested Guide for U. S.
Department of Energy Facilities
Author: S. Barisas, J. Pouch, L. Habegger, and T. Sisles
D OC.Type: Audit Manual (August 1983)
Abstract: This manual was prepared for use by any IX)E facility as an aid for conduct-
ing an internal environmental proctection audit. The manual consists of
sets of audit qiEstions organized with respect to specific areas of envir-
onmental protection (e.g., nonradioactive air pollution, asbestos, radio-
riuclides, toxic substances, PCB materials, hazardous waste, laboratory
quality assurance). The questions within each specific area were developed
fran existing DOE orders, executive orders, federal statutes and regulat ions.
The manual provides a methodology hith has the potential to be used by
facilities other than DOE’s.
Source: Argonne Nat’ 1 Lab (Report #ANL/EES-IM-237), Energy and Environmental Systems
Division; Integrated Assessment and Policy Evaluation Group, Argonne, IL.
Title: Multi-Media Canpliance Audit Inspection Procedures
Author: National Enforcement Investigations Center, EPA
Dcc. Type: Audit Manual (February 1983)
Abstract: Details the procedures used by EPA or state inspectors authorized to
conduct multi-media ccxnpliance inspections of facilities. The approach
is intended to nore effectively schedule the time of investigatory
personnel and support a rational system for analyzing the ccinpliance
status áf particular sources. The roles and responsibilities of in-
spectors are also discussed.
Source: U.S. EPA, National Enforcement Investigations Center, Federal
Center, Bldg. 53, Box 25227, Denver, Colorado 80225
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Title: A Practical Guide to Plant Environmental Audits
Author: H. William Blakeslee and Theodore M. Grabowski
t1 c. Type: ook (February 1985)
Abstract: Provides step—by—step advice on auditing a plant’s ccm p1iance for air,
water, waste, oil spills, toxic substances and others. Provides information
for the engineer responsible for conipliance, especially at small and
mediuit -sized manufacturing and chemical plants.
Source: Van I bstrand Rheinhold Company, Inc., 135 West 50th Street, w York, NY,
10020.
Mr. Blakeslee is with Certain ed Corporation, 1400 Union Meeting Road,
Blue Bell, PA 19422. Mr. Grabowski is with Sun Refining and Marketing
Company.
Title: “Can You Trust Your thvironmental Auditing Program? Organizational Issues
In Establishing and Improving Environmental Auditing Programs”
Author: Alfred A • Marcus and Mark V. Nadel
I c. Type: Report (t vember 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 establish-
ing or uograding 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: Regulatory Reform Staff (PM—223), U.S. EPA, 401 M Street, S.W., Washing-
ton, D.C. 20460
Prepared under contract by Battelle Menorial Institute, Human Affairs
Research centers, 4000 N.E. 41st Street, Seattle, sc 98105.
Title: “An Approach to ES & H Assurance Programs for Institutions”
Author: Sandia National Laboratories, Andrew Ellingson and
tharles Trauth, Jr., editors
tbc. Type: 1 port (September 1982)
Abstract: A collection and condensation of material contained in 17 separate
Sandia National Laboratories’ publications concerning Environmental,
Safety and Health (ES&H) programs. The report provides a detailed
description of the c nponents of an ES&H program including assurance,
staff review activities and appraisals, institutional errergency re—
sponse programs and institutional accident investigations.
Source: Prepared by Sandia National Laboratories, Albuquerque, Naw Mexico 87185.
Available from National Technical Information Service, U.S. 1 partment
of Comerce, 5285 Rrt Ryal Rd.,, Springfield, VA 221 l.
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C. CONFIDENTIALITY and DISCLOSURE
Title: “Can &at You Know Hurt You as Much as What You Don’t Know?”
Author: Phillip D. Reed
Doc. Type: Journal article
Abstract: Many corporations have adopted environmental auditing which the author
sees as evidence of the maturity of pollution control law. He asserts
that environmetnal compliance is increasingly seen as good business rather
than a problen that will go away if ignored. However, as a result of the
relative novelty of environmental auditing, the legal consequences are
uncertain, and the confidentiality of environmental audits has become a
major concern. The author reviews the law and EPA policy governing access
to a company’s environmental audits. The law clearly allows protection of
audits from discovery in civil actions under some circumstances but a
question mark hangs over how EPA will deal with audits in administrative
enforcenent actions. The author suggests that removing that uncertainty
with a policy of ignoring audit reports in routine enforcement could sig-
nificantly encourage auditing without weakening enforcement.
Source: Environmental Law Reporter, Vol XIII, No. 10, October 1983, pp. 10303-8.
Mr. Reed is with the Environmental Law Institute, 1346 Connecticut Avenue,
NW, Washington, D.C., 20036.
Title: “Issues of Confidentiality and Disclosure In Environmental Auditing”
Author: Malcolm C. Weiss
Doe. Type: Paper (November 1983)
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 confiden-
tiality of audit information.
Source: Prepared under contract for the Regulatory Reform Staff (PM-223), U.S.
EPA, 401 N Street, S.W., Washington, D.C. 20460.
C.-1
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Title: “Safeguarding Confidential Business Inforniat ion”
Author: DonaldJ. Henz
Doc. Type: Conference paper
Abstract: Once a firm decides to implenent an environmental auditing program,
decisions will have to be made about keeping audit generated information
confidential. Information concerning capacity, prOduction rates, process
fl i, expected life of facilities, expenditures, etc., will be gathered
in an audit and, if not kept confidential, may be used against its pro-
ducer. Methods to enhance confidentiality of business information are
discussed in the context of two “golden rules”: (1) never volunteer
information and (2) maintain a confidential mentality.
Source: PED(X) Environmental, Inc. 11499 Chester Road, Cincinnati, Ohio, 45246.
Presented at the 76th Annual Meeting, Air Pollution Control Association,
Atlanta, Georgia, June 1983.
Title: “Duties to Report or Disclosure Information on the Environmental Aspects
of Business Activities”
Author: Environmental Law Institute
Doc. Type: Draft Report (Septanber 1984)
Abstract: The report delineates corporate obligations to record and report information
on the environmental and health impacts of their activities and EPA obli-
gations to disclose or protect such information. It covers: (1) selected
statutes and regulations; (2) SEC requir iients; (3) caimon law; (4) ethical
obligations under professional codes of conduct, and (5) EPA’s obligations
to report cc npliance information to the public. The report was prepared to
lay out the factual background for EPA examination of environmental audit
policy options.
Source: Regulatory Reform Staff, PM-223, EPA, 401 M St., SW, Washington, DC 20460.
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D. BENEFITS OF ENVIRONM N AL AUDITING
Title: “Benefits to Industry of Envirormiental Auditing ’
Authur: Arthur D. Little, Inc., Center for Environmental Assurance
Doe. 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 t. o main effects: (1)
increased management effectiveness, and (2) increased management com-
fort or security that the company is meeting its legal, corporate and
ethical requir nents. Identifies measures to evaluate those effects.
Source: Regulatory Reform Staff (PM-223), U.S. EPA, 401 M Street, S.W.,
Washington, D.C. 20460.
Title: “Benefits of Environmental Auditing: Case Examples”
Auttor: Arthur D. Little, Inc., Center for Environmental Assurance
Doe. Type: Report (Dec cber 1984)
Abstract: l)ctnnents the benefits of envirorinental. 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 fr an having conducted
a ninber of audits over a period of time. Provides insights into tow
environmental auditors conduct their field rk, what type of situations
they are likely to uncover, and how facility-level environmental management
can improve as a result of an audit.
Sairce: Regulatory Reform Staff (PM-.223), U. S. EPA, 401 M Street, SW,
Washington, D.C. 20460.
Title: “Environmental Auditing Programs: Benefits to the Environment and
Gave rrinent”
Author: Edwin H. Clark, II
Doe. Type: Report (June 1983)
Abstract: Analyzes the expected benefits to the environment, state and federal
government agencies from the spread of environmental auditing. The
benefits appear to be quite large depending on the number and types of
private auditing programs adopted and on the nature of government re-
sponses to these programs. Identifies policy options which may influ-
ence the ina iitude of expected benefits.
Sciurce: Regulatory Reform Staff (PM-223), US. EPA, 401 M Street, S.W.,
Washington, D.C. 20460.
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E. INI1JSTR EXPERIENCE ANT) PERSPECTIVES
Title: “Current Practices in vironmental Auditing”
Author: A.D. Little, Inc., Center for Environmental Assurance
0>c. Type: Report
Abstract: This report provides a discussion of environmental auditing followed
by detailed descriptions of five individual audit programs. It has
been developed to help further the underétariding of environmental
auditing and how various cc ipanies approach the subject. The de-
scriptions of the environmental auditing programs of the five c-
panies in this report are based on in-depth interviews with the com-
panies’ audit program managers. Examples of the various program docu-
ments —--— checklists, protocols, audit reports, etc. ——— obtained
frcxn each cc pany are included in the ccrnpany profiles to help the
reader further understand the nature and scope of each program and
sai e of the key alternatives available in designing an audit program.
The canpanies profiled in this report represent a diversity of audit-
ing approaches, as well as a variety of industry segments. All have
management support for their programs and have made significant corn-
mitments to their environmental auditing effort. Each canpany will-
ingly agreed to discuss its audit program in detail and provide ex-
amples of its program approach and supporting materials.
Source: Regulatory form Staff, PM—223, U.S. EPA, 401 M St., SW, Washington,
D.C., 20460. Report to U.S. Environmental Protection Agency, 1 b.
EPA—2300983—006; February, 1984.
Title: Environmental Auditing Case Studies
Author: Arthur D. Little, Inc., Center for Environmental Assurance, for the Edison
Electric Institute
DDc. type: Report (1984)
Abstract: Similar to “Current Practices in Environmental Auditing t , this
publication focuses on environmental auditing systems in the
electric utility industry. E scriptions of five electric utility
cc npanies audit programs are presented in considerable detail.
Source: Edison Electric Institute, Environmental Auditing Task Fbrce,
1111 Nineteenth Street, N.W., Washington, DC 20036.
F — 1
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Title: “Profiles of Environmental Auditing Programs”
Author: Arthur D. Little, Inc.
Doe. Type: Report (1980)
Abstract: Surveys provided the information frc n v ich profiles of 17 corpora-
tions’ environmental auditing programs cctnprising this report are
drawn. The profiles slow a diversity and creativity of auditing
models. The implications of the profiles are discussed in a cai pan-
ion piece,”A Survey of Environmental Auditing.”
Source: Center for Environmental Assurance, Arthur D. Little, Inc.,
15 Acorn Park, Canbridge, Massachusetts, 02140.
Title: “A Utility’s Experience With An Environmental Quality Asses ent
Program”
Author: Michael F. Basta
Doe. Type: Conference paper
Details the background, scope arxi desi of the Pennsylvania Power
arid Light (PP&L) auditing program to achieve environmental ccxnpliance
at its facilities. Explains the auditor’s role as providing manage-
ment assistance to the line organization so they may carry out the
canpany’ s policies. Examines how two key business documents supply
guidance, the assessment process and follow-up response. PP&L advo-
cates auditing as a way that industry can take a leadership role in
helping to improve the environmental regulatory process.
Source: Pennsylvania Power a ix! Light Canpany, T North Ninth Street, Allen-
town, Pennsylvania, 18101. Presented at the 76th Annual Meeting of
the Air Pollution Control Association, Atlanta, Georgia, June 1983.
Title: “Self-Auditing Program Monitors Canpliance”
Author: Staff
Doe. Type: Journal paper
Abstract: Robert Cutler of Olin Corporation, discusses aivirorinental auditing
based on his experience as ager of the Regulatory Canpliance Audit
I partment. He believes a successful audit program r uires (a) good
people, (b) analysis of the regulatory requir oents applicable to a
canpany’ s operations, and (c) that the auditing office be kept indepen-
dent of the activities being audited.
Source: Hazardous Waste and Pollution Management Bulletin , Vol.1, B303, February
10, 1983, pp 1-2.
E-2
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Title: “Environmental Auditing - A Timely and Effective Tool”
Author: Stephen T. MacIn tyre
Doc. Type: Journal paper
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 s1x uld 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. Macintyre is with Rochester Gas arid Electric Corporation, 89 East
Avenue, Rochester, NY 14649.
Title: “Environmental Auditing and Inspections 1 ’
Author: t vid A. Giarinotti
Dcc. Type: Report Chapters
Abstract: A general description of the elements of an erwirorlDentai. auditing
program including: company description, policy and organization,
categorization of facilities, internal procedures for reporting environmental
matters, and issues with unascertainable aspects. A section discusses
the issue of disclosure, concentrating on attorney-client privilege and
the rk product doctrine. The assertion is made that cminications
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
Q-iangthg Legal Environment (Practicing Law Institute, New York; Sept. 1983.
Mr. Giannotti is with Occidental Petroleum Corporation, 10889 Wilshire
Blvd., Los Angeles, C k 90024.
Title: “Environmental Auditing: The Keystone to a Management Compliance,
Control and Risk Assessment Program”
Author: Robert W. Cu.tler
Doc. Type: Journal paper
Abstract: Establishes a framework arid analyzes characteristics of a viable en-
vironmental auditing program. Focuses on top management’s ccinmthnent
as the ke to a successful system. Personnel training, preparation,
field work and reporting are also considered basic aspects of a regula-
tory auditing program.
Source: Environmental Analyst , April 1982, pp. 12—16.
Mr. O.itler is Manager, Regulatory Audits, Olin Corporation, 120 Long
Ridge Rd., Stamford, cr06904.
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Title: “EnvLrom ental Auditing Policy An Exploratory Analysis fran the
Corporate Perspective”
Aut1x r: Martin A. Smith
Doc. ‘I rpe: University paper (May 1983)
Abstract: Examines tr w corporations might respond toward envirormental auditing
as a tool to achieve manag nent goals, both for corporate activities
re1at 3 to the envirornent arid for the canpany as a whole. The autlxr
establishes three general categories as policy alternatives: (1) tradi-
tional. non-auditing controls; (2) informal auditing; and (3) formal
auditing. These categories form the vertical canponent of a matrix
nploying “criteria for choice” as the 1- ri onta1 canponent. This analy-
sis concludes that after costs and benefits are weighed, corporate policy
slx,uld include formal auditing as a management tool.
Source: Institute for Environmental Studies, University of rth Carolina,
311 Pittsboro Street 256H, Chapel Hill, North Carolina, 27514.
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F. ENVIRONMENTAL IMPAIR 1ENT LIABILITY/RISK ASSESSMENF
Title: “Environmental Risk Assessments and Environmental Audits”
Autt r: Richard S. Golob, Executive Editor
Doc. Type: Journal paper
Abstract: Presents an overview of insurance requirsiients and policy options for
firms mandated to carry insurance to meet RCRA regulations. Includes
s .m naries of insurance policies covering non-sudden pollution and pro-
files of environmental auditing and risk assessment firms.
Source: Hazardous Materials Intelligence Report , August 20, 1982, pp. 1-8.
Title: “New Perspectives on Corporate Risk and Ways to Reduce It”
Author: Michael M Gibson and Paul D. Fahrentlxld
Doc. Type: Journal paper
Abstract: Part I: The authors suggest that corporate environmental affairs will
change frciu being reactive to anticipatory in the relationship between
corporate product ion and environmental activities. (k e need for this
anticipatory approach arises frcn “toxic tort” cases where liabilities
may exceed the net worth of the canpany.
Part II: Discusses attorneys’ role in private-sector environmental
audits in the cont t of information gathering and confidentiality.
Explores ccinpeting d nar*ds 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 judgnent, how to protect confidences and secrets, and what
may occur when criminal conduct is found.
Source: The Environmental Forum , Vol.1, No.11, March 1983, pp. 35-41.
Title: “Envirorinental Impairment Liability Insurance and Risk Assessment”
Author: Paul Milvy
Doc. Type: Journal paper
Abstract: Following a brief discussion of the insurance industry’s initial atteiipts
to insure against pollution episodes, the paper focuses on environmental
impairment liability (EIL) insurance. ELL covers costs arising frcin
non-sudden events, a type of coverage which was not previously available.
There are two main risks to be evaluated by riderwriters 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 Fori.m , Vol.1, No.6, October 1982, pp. 30-37.
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G. FEDERAL, STATE and LOCAL PERSPEC 1VES and ACTIVITIES
Title: “Beyond the Battleground: A (Non) Regulatory Perspective on Erwironmental
Auditing”
Author: Karen Blumenfeld and Mark }laddad
Dcc. I rpe: Article (March 1983)
Abstract: Traces the efforts of EPA to encourage private- sector environmental audit-
ing while enhancing its public benefits. It analyzes EPA’s evolving
approaches and describes a three pronged approach: Endorsenent , publicly
supporting environmental auditing, reinforced with visible Agency
activities; Analysis , developing information and data to further understand
and shape future directions of environmental auditing; and Assistance ,
including technical assistance to states and companies interested in
exploring environmental auditing approaches.
Source: Regulatory Reform Staff (PM-223), U.S. EPA, 401 11 Street, S.W., Washing-
ton, D.C. 20460.
Title: “Environmental Auditing: A Managenent Tool and Potential Regulatory Reform”
Author: Leonard Fleckenstein
Doe. Type: Conference paper
Abstract: Provides an EPA perspective on auditing, discusses EPA’s past efforts and
potential future roles vis-a-vis EA, suggests a need to define criteria
for elei ents of effective EA syst iis, and identifies EA policy issues
which may be formally addressed by EPA.
Source: Regulatory Reform Staff, PM-223, EPA, 401 M St. SW, Washington, DC 20460.
Presented at the 77th annnual meeting of the Air Pollution Control Asso-
ciation, San Francisco, Ck, June 1984.
Title: “Environmental Auditing and North Carolina: Regulators Encourage Use of
a Catalyst for Environmental Protection
Author: William C. Ross, Jr.
Dcc. Type: Conference paper
Abstract: Describes how the encouragenent of environmental auditing fits into en-
vironmental regulatory programs in North Carolina. Views auditing as a
way to encourage ccznpliance and cauplenent enforcenent programs. Reviews
the characteristics of t auditing programs in North Carolina: (1) the
Texasgulf systen; and (2) the city of Raleigh systen. The state is cau-
tiously optimistic that auditing is pr noting better environmental per-
formance.
Source: Office of Legal Affairs, North Carolina Department of Natural Resources
and Canrnunity Develo inent, P.O. Box 27687, Raleigh, North Carolina, 27611.
Presented at the 76th Annual Meeting of the Air Pollution Control Asso-
ciation, Atlanta, Georgia, June 1983.
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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: A.D. Little hosted a discussion of environmental auditing among interested
states. These meeting notes highlight 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: "Environmental Auditing Workshop — Sunmary of Proceedings"
Author: Regulatory Reform Staff, EPA
Doc. Type: Report (October 1983)
Abstract: Summarizes discussions at EPA's Environmental Auditing Workshop in
Alexandria, Virginia on June 9, 1983. Highlights include: prepared
remarks by the morning's seven speakers; a short morning question and
answer session; an afternoon panel discussion; and reports from each of
seven small discussion groups.
Source: Regulatory Reform Staff (PM-223), U.S. EPA, 401 M Street, S.W.,
Washington, D.C. 20460.
Title: "EPA's Environmental Auditing Outlook: The Compliance and Enforcement
Office View"
Author: James R. Edward
Doc. Type: Speech
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 EPA1s 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, MN.
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Title: “New EPA Initiatives in Environmental Auditing ’
Author: C. Ronald Smith
Doc. Type: Speech
Abstract: Presents a brief definition of Environmental Auditing, a history of
EPA’s thinking on the subject, an EPA Policy Office perspective on
auditing, and describes sane new initiatives EPA is taking to encourage
auditing.
Source: Regulatory Reform Staff, PM-223, EPA, 401 M St. SW, Washington, DC, 20460.
For presentation at the HazNat Southwest Conference, Houston, D
Nov nber 1, 1984. Mr. Smith is Director, Office of Standards and
Regulations, U.S. EPA.
Title: “Opportunities for Promotion of Environmental Auditing Througb
State-Level Initiative: Observations and Recomendations 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 re-
ports, journal articles, sri informal survey of all states, and conver-
sations with state and industry representatives. Suggests alternate
methods for promoting environmental auditing at the state level through
legislation, administrative actions, enforcenent programs, technical
support and numerous private-sector efforts. Identifies methods for
promoting environmental auditing among state industries and public-sec-
tor entities, arid discusses what steps will be taken to institutionalize
the state’s auditing initiative. The authors make reccinmendat ions
to provide a policy framec. ork arid guidance to encourage environmental
auditing in North Carolina.
Source: Regulatory Reform Staff, PM-223, EPA, 401 M St. SW, Washington, D.C. 20460
Title: Suninary of Proceedings: Environmental Auditing Conference for
Federal Facilitfes in Western States
Author: JRB Associates, editor
Doc. T ype: Conference Summary
Abstract: A comprehensive st rrnary of presentations and discussions by Federal agency
program and facility managers, EPA, industry and consultants at an
EPA-sponsored conference in February 1984.
Source: Regulatory Reform Staff, PM-223, EPA, 401 M St. SW, Washington, DC, 20460
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