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Compliance Auditing


Environmental compliance auditing is a non-punitive, systematic and periodic review of the status of environmental compliance in regulated operational areas.  This review can be done by an external individual or team of people or an individual or team of people internal to the operation of the installation, facility, or site providing that the auditors are independent of the audited operations.  These audits are done on a cyclic basis to ensure compliance with pertinent Federal, State, and local regulations is maintained and new or revised applicable regulations are incorporated into day-to-day operations and activities. 


EPA encourages all regulated entities to audit themselves routinely and supported implementation of this process when they first issued the July 9, 1986 "Environmental Auditing Policy Statement" (51 FR 30466) and later the 22 December 1995 ''Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations'' (60 FR 66706).   This policy was updated again and most recently on April 11, 2000 and is commonly referred to as the ''Audit Policy'' (65 FR 19618).  The EPA Audit Policy provides incentives for self-disclosure of audit findings to EPA (which may include a reduction of penalties) if the regulated facility satisfies the nine conditions for penalty mitigation explained in the EPA Audit Policy. Under the automated eDisclosure system, regulated entities (including federal facilities) will be able to resolve certain routine types of disclosures. EPA is launching the eDisclosure system to continue the benefits of self-disclosure policies and provide penalty mitigation and other incentives for companies that self-police, disclose, correct and prevent violations. See EPA's website for details on the incentives to self-audit and disclosure and the self-reporting process using e-Disclosure.

Also in support of self-auditing, the EPA issued an Environmental Audit Program Design Guidelines For Federal Agencies (EPA 300-B-96-011) and a series of 14 audit protocols starting in 1998 and ending in 2005.  Topics addressed included:

• Generation, Treatment and Disposal of RCRA Hazardous Waste
   (regulatory overview; additional auditing aids)
• Universal Waste and Waste Oil under RCRA
    (regulatory overview of universal waste; regulatory overview of used oil)
• RCRA Regulated Storage Tanks
   (regulatory overview; additional auditing aids)
• CERCLA/SARA (cleanup)
   (regulatory overview; additional auditing aids)

• EPCRA (emergency preparedness/community right-to-know)
   (regulatory overview and additional auditing aids)

• FIFRA (pesticides)
   (regulatory overview; additional auditing aids)
• RCRA Subtitle D (solid waste)
   (additional auditing aids)
• Clean Water Act
   (regulatory overview of wastewater treatment; additional auditing aids)
• SDWA (drinking water)
   (regulatory overview; additional auditing aids)
• RCRA Subtitle C (hazardous waste)
   (regulatory overview; additional auditing aids)
• Stormwater
   (regulatory overview; additional auditing aids)
• PCBs, Lead-based Paint and Asbestos
   (regulatory overview of asbestos; additional auditing aids)

None of these EPA audit protocols nor the audit program guidelines document have been updated since they were originally issued.  With the exception of the Stormwater protocol, the EPA audit protocols were based on the U.S. TEAM Guide which was developed for multiple Federal Agencies which partner together for the ongoing updating of the U.S. TEAM Guide and associated State Supplements.


In addition to audit protocols there are numerous tools, databases, and guidance documents which can be used to enhance the audit process and ensure regulations are being accurately applied.  These tools, databases and guidance documents can be found in the Environmental Compliance Program Area under the headings "Regulations, Guidance, and Policy", "Supporting Information and Tools" and "Lessons Learned->Compliance Auditing."

Executive Order Requirements for Federal Agency Environmental Auditing Programs and Regulatory Compliance

Federal facilities were mandated to comply with federal, state and local environmental regulations in 1978 by Executive Order 12088. Despite compliance being required since 1978, it was with the issuance of the 1992 Federal Facilities Compliance Act which waived sovereign immunity for federal agencies from fines associated with hazardous waste and underground storage tank violations that brought attention to the need for federal facilities to comply with Federal, State, and local environmental regulations. 


The need to conduct environmental compliance audits was further supported by Executive Order 13514 of 5 October 2009 (rescinded) and EO 13693 of 19 March 2015 which encourage the use of environmental management systems (EMS) by Federal Agencies/facilities.  Inherent in the implementation of EMS is the conduct of environmental compliance audits. 

For a discussion of factors to consider in the development of an audit program, click here.
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Last Updated: August 23, 2016