ENVIRONMENTAL COMPLIANCE AUDITS - A PROACTIVE APPROACH

摘要

Virtually all private and public facilities in the United States are subject to a dizzying array of complex and confusing environmental and chemical safety laws. Due to the constant proliferation of complex new environmental and chemical safety regulations, deregulation of the utility industry, the current expansion of power generating capacity, and residual contamination still to be cleaned at formerly operated manufactured gas plants, it can be difficult for utilities to identify - let alone comply with - all of the environmental, chemical safety and permitting laws that apply to their activities and physical structures. Moreover, with EPA stepping up its enforcement efforts, increasing fines for non-compliance, and embarking on a national enforcement initiative aimed at coal fired electric utilities, it is crucially important for utilities to operate in compliance with applicable laws. The best way for a utility to identify applicable laws, assess its compliance status with such laws, and to acquire the information necessary to develop successful long-term compliance strategies is by conducting a comprehensive compliance audit. This paper: (1) explains EPA's enforcement approach and discusses recent enforcement activities focused on the utility industry; (2) defines what a "compliance audit" is and the different types of audits that can be performed; (3) highlights the advantages and disadvantages of performing audits; (3) details the audit process; (4); provides a brief overview of the regulatory framework that encourages self-auditing; and (6) summarizes why an Environmental Management System makes sense.