Environmental Auditing and Audit Disclosure in a New Era

CHANGES IN AUDIT POLICY • Most state laws and policies are largely unchanged, but EPA last year moved its Audit Policy into an “eDisclosure” system – online portal • Excepting some straightforward EPCRA disclosures and new owner audits, you don’t get an answer ‒ It’s just a prophylactic filing in the event the agency later pursues enforcement • EPA responsiveness to audit disclosures was always spotty, but it’s now unresponsive by design • If you don’t get an answer until they’ve already decided to enforce, how likely are they to honor the disclosure? • Leaves a high level of uncertainty over an indefinite period


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