INTERNAL COMPLIANCE AUDITING Background, Process, and Tools for Success presented by: Ronald Taylor, Environmental Affairs Compliance Manager

EPA states: … “it is USEPA policy to encourage the use of environmental auditing to help achieve and maintain compliance and identify / correct unregulated hazards”…

T HE EPA A UDIT P OLICY 1.Systematic discovery though audits and management systems 2.Voluntary discovery 3.Prompt disclosure (defined as within 21 days) 4.Discovery is independent of government or 3 rd party plaintiff 5.Correction and Remediation

T HE A UDIT P OLICY 6.Prevent reoccurrence 7.No repeat violations 8.Some violations are excluded 9.Cooperation

EPA I NCENTIVES FOR A UDITING Gravity based penalties will not be pursued. (all 9 elements in place) 75% reduction in gravity based penalties. (elements 2 – 9 in place) No recommendation for criminal prosecution. (elements 2 – 9 in place) No routine request for audit reports. Kentucky, if voluntary disclosure, will not seek civil penalties.

H IGHER E DUCATION F OCUS Region 1 began in 2004 – initial focus on educating the community – basic compliance – best management practices – sustainability UK received communication in 2007 Additional communication to UK Healthcare in 2008

A DVANTAGES Increased awareness Helps drive accountability Helps meet audit policy criteria Recognition of exemplary practices Identification of improvement opportunities Proactive response to compliance

K EYS FOR S UCCESS Upper management support Good audit tools Well defined audit criteria Timely follow up and closure An integrated approach

C HALLENGES Audit scope identification Effective and timely closure Corrective action verification Accountability Potential for FOIA requests

Knowledge is Power. To be forewarned is to be forearmed quoted from : “Environmental Audits and Inspections: What Every U (and University Attorney) Should Know Michael Sermersheim and Ronald Baylor, June 2004

T HE P ROFILE Establishes audit scope Based on activities within audited entity Accuracy is key

T HE A UDIT Applicable questions built from profile Used for field evaluation Good training tool

C ORRECTIVE A CTION T RACER Compiles identified compliance issues Tracking tool for completion May also add compliance due dates and recommendations May send reminder messages

S UCCESS S TORIES Location asked for blank audit to use in training Last 2 campus regulatory inspections resulted in no Notices of Violation Enhanced communication between EMD and SAA’s