Companies can benefit from performing internal environmental audits in several different ways. Rather than waiting around the EPA to investigate, owners should take the initiative to perform their own audits, checking for any and all environmental violations and compliance issues. By performing their own internal environmental audits, companies can take the necessary action to fix any violations that were found, fast-tracking their way towards compliance. Of course, this is just one of the many reasons why company should perform their own environmental audits…
The EPA actually has an incentive program in place to encourage in-house audits along with the disclosure of environmental violations. Formally referred to as “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations,” the EPA Audit Policy is a program which rewards companies for voluntarily identifying, disclosing and fixing violations and compliance issues.
In order for a company to qualify for the EPA Audit Policy program, it must meet a total of nine specific conditions. Here is a brief overview of these conditions set forth by the EPA:
- Discovery through the company’s own environmental audit or compliance management system (CMS).
- The discovery was made voluntarily and not through a monitoring or legal auditing procedure.
- Written disclosure of the violation was sent to the EPA within 21 days of discovery (some jurisdictions may require shorter times).
- Independent discovery of the violation was made before EPA.
- Remediation was made within 60 days of the violation’s discovery.
- New practices enacted to prevent similar violations in the future.
- This same violation can not occur within the next 3 years.
- Violations which result in serious or life-threatening harm are not eligible for the EPA Audit Policy program.
- The company or representative responsible for disclosing the violation must cooperate with the EPA.
If a company is able to meet the conditions previously mentioned, they are eligible to receive incentives from the EPA. You can read the official PDF file for more information, but the incentives are based around penalty reductions. For instance, ‘gravity-based’ penalties are completely eliminated as long as the company meets all nine conditions. If the company met all conditions with the exception of systematic discovery, they will receive a 75% reduction of gravity-based penalties. This is a huge benefit that can yield a substantial financial savings for companies. Companies that meet these nine conditions are also not recommended for criminal prosecution by the EPA.