Audit User’s Survev Results Part I Ouestion 7 CountType of Industry or Metals or Other or farm equipment or Health care products (including 2 Energy production (non-utility) or petroleum 2 Electric or gas 2 Consumer durable or nondurable goods 2 Aerospace or defense equipment Food-beverages or tobacco I I Construction or building materials Other industries given Plastics (Injection Blow Molding) Instruments Manufacturing Federal Government Secondary Education Solvent Recovery RCRA Permit Page 2 of Tuesday, December 22, 1998 Audit User’s Survey Results Part I Ouestion Learn of Audit Policy Count In-house or outside counsel Federal Register 9 Other 6 Trade 5 Seminar or conference 3 Trade 2 Trade association; In-house or outside counsel; Trade publications Trade association; Federal Register; Seminar or conference; In-house or other counsel; Trade publications Semmar or conference; Outside counsel; Other in-house or outside counsel; Seminar or conference In-house or outside counsel; Federal Register; Semmar or conference; Trade publications; Other Federal Register; In-house or outside counsel; Trade publications Federal Register; In-house or outside counsel Trade publications Other Responses Given Local Inter-Industry Environmental Organizations regulators. Discussions Familiar with its development since 1994 EPA V Mini-Mill initiative EPA’s “Mini-Mill” Initiative Was unaware of policy at time of ...
Ouestion 7 Type of Industry or Metals or Otheror farm equipmentor Health care products (including Energy production (non-utility) or petroleum Electric or gas Consumer durable or nondurable goods Aerospace or defense equipment Food-beverages or tobacco Construction or building materials Other industries givenPlastics (Injection Blow Molding)Instruments ManufacturingFederal GovernmentSecondary EducationSolvent Recovery RCRA Permit
Tuesday, December 22, 1998
Count
2222
II
Page 2 of
Count
9 6
3 2
Audit User’s Survey Results Part I Ouestion Learn of Audit Policy In-house or outside counsel Federal Register Other Trade Seminar or conference Trade Trade association; In-house or outside counsel; Trade publications Trade association; Federal Register; Seminar or conference; In-house or other counsel; TradepublicationsSemmar or conference; Outside counsel; Other in-house or outside counsel; Seminar or conference In-house or outside counsel; Federal Register; Semmar or conference; Trade publications; OtherFederal Register; In-house or outside counsel; Trade publicationsFederal Register; In-house or outside counsel Trade publications Other Responses Given Local Inter-Industry Environmental OrganizationsDiscussions regulators.Familiar with its development since 1994EPA V Mini-Mill initiativeEPA’s “Mini-Mill InitiativeWas unaware of policy at time ofContacted EPA concerning problemEnvironmental Publication
Tuesday, December 22, 1998
Audit User’s Survev Results Part I Question 9Disclose Policy CountYes24 Don’t know N O Disclose Policy Explanation Why or Why Not Yesthe violationsISrequired by regulations and/or statutes. YesTo correct an oversight YesViolations would always be disclosed, but the EPA Audit Policy creates an incentive for comprehensive self-auditing Yes under TSCA penalty policy.Would have used self disclosure YesYes, if it was required by a statute. Company policy to maintain total complrance all EPA or other agency’s YesIts YesCompany policy YesIn the facility’s current permitting was beneficial to disclose with or without the Audit it Policy. The facility does believe the Audit PolicyIS necessary however. YesCorporate policy to disclose. Yesbeing purchased. Discovery of violation came during due diligenceCompany was YesOur corporate Weculture is to “do the right must work with our regulators, citizen groups and our neighbors to accomplish our goal. YesAs a result of an outside complrance review, we were apprised of the violation at which time it was disclosed YesTo stay in compliance with laws YesWe would have self-disclosed under the “old (Circa 1987) “Recordkeeping and Reporting Rule TSCA Sections 8, I2 and 13 Enforcement Response Policy Published by the Office of Compliance OPPTS, YesOur policyISlaws, rules, and regulations. This includes reporting noncompliance comply with all to incidents. YesWe don’t knowingly violate government regulations, disclosure was determined not to be a violation. YesPer company policy NoNo protection from fines. Don’t know Not sure 100%. The Audit Policy was a clear motivator to report Don’t knowIn the absence of the policy, circumstances would have required further review and analysis of all relevant factors Don’t knowConsiderations: “paper violations; no endangerment; preventive and corrective action immediately undertaken regardless of Policy’s existence Don’t knowReporting violation only no threat to environment. Plant has never had Federal EPCRA audit,SO good chance we would not be caught if we did not report. However, we wanted to be in compliance and correct past errors. However, without the certainty of fine reduction, it may have been too expensive to self-report a violation
Tuesday, December 22,
Audit
Don’t know
Don’t know
Don’t know
Tuesday, December 22,
User’s Survev Results Part I
We probably would have disclosed under the voluntary disclosure
Potential was the absence of a permit, which would have been applied for. Whether it would have been separately reported as a violation is uncertain.
It was only a
the policy we may not have reported it
Page
of 11
Audit User’s Survev Results Part I Question Typeof Violation EPCRATSCAOther
TSCA: CAARCRA: EPCRA; CWA; RCRA; CWACWA: C W A
Other Violation Given SDWAWe had no violations.II ReportingSDWA
Ouestion 11 Duration of Audit Not applicable I-2 days 3-7 days 6 months or longer l-3 l-5 months 3-7 days; Not applicable l-2 days; I-3 weeks
Tuesday, December 22,
Count 17 13 7 A
Count
1 1 9 6 5 2 I
Page 6 of 11
Audit User’s Survev Results Part I
Ouestion Affiliation of Auditor In-house engages audited-In-house-independent of auditedOutside contractorOther
In-house-Independent of activity audited; Outside contractor In-house-engages in activity audited; Outside contractor: In-house-engages in activity audited; contractor
Other Auditor Responses Given
Wasn’t any
Count 19 13 IO
Had contractor conduct but found no violations. New in-house environmental manager
Tuesday, December 22, 1998
Audit User’s Survev Results Part I Ouestion 13 Ouestion amScope of ProgramCount Formal Audit Progr Count Yes783 5 No Selected media and statutes Informal ProgramI
Ouestion 13b hlost facilities Some Other Other Facilities Given Only one facility
Tuesday, December 22, 1998
Count 2274
Ouestion Duration of the Audit Under the Program 3-7 days I-2 days l-3 weeks 6 months or longer I-5 months Continuous as part of in-house environmental program days; 3-7 days: Depends on facility I-2 days; 3-7 days
Count 13942
Count
2
2 2
Audit User’s Survey Results Part I Question Affiliation of Auditor In-house-independent of activity audited contractor In-house-engages audited In-house-independent of audited; contractor In-house-engages in activity audited, contractor In-house-engages in activity audited; Independent of audited Outside contractor; Other Other In-house-engages in activity audited; Outside contractor; In-house, independent of activity audited In-house-engages in activity audited; Outstde contractor (on In-house-engages in activity audited; In-house, independent of activity audited; Outside contractor In-house-engages in activity audited; In-house, independent of activity audited; Other Other GivenSome audits combination of site and off site employees.Combination of in activity and independent of activity Outside counsel
Tuesday, December 22, 1998
I
Page 9 of 11
Audit User’s Survev Results Part I
Q u e s t i o n Frequency of Audit Once every three to five ears
Once every year
Once every two years
Other
Once every year; Once every two years Once every three to five years; Other
Other Frequencies Given
Monthly
Just being developed
Monthly to once every three years
Continuous
Once every six months
Count 9
Once every three years by corporate Once every quarter by business unit. Some every year, others every two
Tuesday, December 22, 1998
8
8
I
Count
Audit User’s Survev Results Part I Question Improvements in Auditing Practices not encourage in programOtherScope of coveredScope of processes coveredScope of covered; Scope of processes coveredScope of covered; Number of people mvolvedScope of media covered; Frequency of auditingScope of media covered; Frequency of auditing; Number of people involved Scope of media covered: Frequency of Number of
Lumber of people mvolved of facilities audited Frequency of auditing; Scope of processes covered
Did not encourage improvements in auditing program. Our improvements are based on our for compliance. Improved follow-up of any findings. Gave us discipline and focus for auditing. Created a partnership or trust between regulator and reporting regulated entity.