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    U.S. Environmental Protection Agency

    New England Office

    Audit Policy

Goals of the Self-Audit Policy

To increase environmental compliance

     To eliminate or minimize fines

     To provide time to come into compliance

What is the Audit Policy?

EPA’s Audit Policy encourages public and private facilities to:

conduct an environmental compliance audit; and,

     disclose and correct any violations that are found as a result of the audit.

Any public or private institution may use EPA’s Audit Policy at any of its facilities at any time.

What Are the Benefits to Your Institution?

    This initiative invites you to use EPA’s Audit Policy to identify environmental violations at your campus, disclose those violations to us, and voluntarily correct them. If specific conditions are

    met, the Policy allows penalty reductions of up to 100% for violations that might otherwise be assessed through an EPA enforcement action. (However, EPA reserves the right to pursue

    penalties for violations from which your institution realized a significant economic benefit).

How Do I Sign Up?

     Submit a letter of intent to EPA. The letter need only state that you intend to conduct an

    audit of your facility and disclose potential violations to EPA under the audit policy. Identify a contact person at your facility.

     Tell us which facility (ies) you propose to audit. Include each facility’s street address.

     Have the letter signed by someone who can legally represent your institution. Send the letter to EPA.

     Send a copy of the letter to your state environmental agency. See the attached fact sheet for a

    list of state contacts.

    You may use the attached sample letter to notify us of your intent to participate.

Applicable Deadlines?

    If violations are revealed by the audit, you must inform EPA of the violations, in writing, within twenty-one (21) days of your receipt of the audit report. (The EPA Audit Web Site includes a sample disclosure form). The Audit Policy states that you must correct the violations within

    sixty (60) days of your receipt of the audit report. However, if you believe that a specific violation cannot be corrected within 60 days, you may contact EPA to discuss an extension. If your audit reveals no violations, simply inform EPA in writing.

    We encourage the preparation of audit reports to help you discover and correct any violations of environmental requirements. You are under no obligation to submit the audit report to EPA.

    Remember: To qualify for penalty reduction or elimination, your report to EPA must satisfy the criteria set out in the Audit Policy. Be sure to read it carefully! Briefly, the policy criteria are:

policy criteria:

    1. Systematic discovery of the violation through an environmental audit or a compliance

    management system;

    1. Voluntary discovery of the violation (not through a monitoring, sampling, or auditing

    procedure required by statute, regulation, permit, judicial or administrative order, or

    consent agreement);

    1. Disclosure of the violation to EPA in writing within 21 calendar days of discovery;

    2. Independent discovery and disclosure of the violation;

    3. Remediation of the harm (if any) caused by the violation and expeditious certification

    of its correction in writing to appropriate authorities;

    4. Preventing recurrence of the violation after disclosure;

    5. That the same or a closely-related violation must not have occurred at the same

    facility within the past 3 years;

    6. That participating institutions cooperate as required by EPA, and provide the Agency

    with the information it needs to determine the degree to which the Policy may be

    applicable to its disclosure of violations; and

     9. Violations resulting in serious actual harm to the environment, or which may have

    presented an imminent and substantial endangerment to health or the environment are

    excluded, as are violations from which your institution realized significant economic

    benefit.

Who Should Conduct the Audit?

The EPA Audit Policy specifies that the audit be an independent review of the facility’s

    compliance status. EPA New England encourages (but does not require) the use of a qualified third party consultant to conduct the audit.

Where Can I Get a Copy of the Audit Policy?

Copies of the complete policy are available on EPA’s web site

    http://www.epa.gov/oeca/orc/apolgurd.htmat http://es.epa.gov/oeca/finalpolstate.pdf or by

    calling the EPA New England Customer Call Center at 1-888-372-7341 (toll free within New England). For access to EPA’s audit home page, visit: www.epa.gov/oeca/ore/apolguid.html.

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