Environmental Auditing and Audit Disclosure in a New Era

WHAT DOES THIS MEAN FOR AUDITS AND DISCLOSURE? • Audit statutes like the Texas EHS APA continue to be vital and important, especially with anticipated federal deference to states • EPA’s Audit Policy and eDisclosure continues to offer some benefit but it’s even less certain than before – use it where there’s a real reason • These “new” approaches to auditing may be less amenable to discrete “findings” and “disclosures” tied to specific statutory, regulatory, or permit violations • Need to think very carefully about what, how & to whom to disclose • Reexamine assumptions underlying your traditional effective compliance auditing program and whether it’s still a fit now

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