EPA to Launch New Self-Audit Web Tool for Fall 2015
By self-auditing and disclosing violations through the web portal, large and small businesses will have a chance to mitigate civil penalties for EPA noncompliance. Under EPA’s Audit Policy and Small Business Compliance Policy, businesses that self-report can receive a Notice of Determination from EPA that provides conditional relief from civil penalties, provided the violations are corrected within a set period of time.
To capitalize on the advantages of EPA’s Self-Audit Policy using the new web tool, businesses must register with the EPA Central Data Exchange (CDX) system.
Two Types of Self-Disclosures
Self-reported violations will fall into two categories in the eDisclosure system: Tier 1 and Tier 2. These labels should not be confused with EPCRA Tier I and Tier II reporting requirements.
Tier 1 violations meet all of EPA’s conditions for self-audit: systematic and voluntary discovery independent of a third party or government, prompt correction or remediation, and cooperation with EPA. Repeat violations and violations that cause actual harm or imminent and substantial endangerments are not eligible for relief under the Audit Policy. Tier 1 will encompass most self-reported EPCRA violations. Tier 1 violations receive an Electronic Notice of Determination (eNOD) in response.
Tier 2 violations are all other disclosures, EPCRA and non-EPCRA. These will be answered with an acknowledgement letter from EPA.
More About EPA’s Audit Policy
To read more about EPA’s Audit Policy, click here: The Advantages of EPA’s Self-Audit Policy
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