Self-Auditing Environmental Compliance: A New Approach

Like all colleges and universities, the University System of Georgia’s (USG’s) 35 campuses and one research institute face a bewildering array of environmental regulations, governing everything from boiler and generator air emissions to the storage and disposal of laboratory chemicals to the stormwater that runs off campus buildings and parking lots.

The environmental and financial cost of non-compliance can be high, and surprise inspections from the United States Environmental Protection Agency (EPA) or state regulators routinely turn up multiple violations, even at campuses that consider their compliance issues to be well managed.

Starting more than 10 years ago, first EPA Region I and then other EPA Regions began focusing on colleges and universities for both compliance assistance and enforcement action. In 2007, EPA Region IV began its initiative, encouraging colleges and universities across the southeast to participate in EPA’s Audit Policy, which offers organizations incentives to conduct self-audits and voluntarily disclose compliance violations.

USG, the largest state university system in Region IV and one of the largest in the nation, decided to use this EPA initiative as an opportunity to strengthen and refine its environmental compliance programs by implementing a unique, system-wide audit program.

As Sandra Neuse, assistant vice chancellor for compliance and operations in the USG Board of Regents Office of Real Estate and Facilities explained, “When we received the letter from the EPA announcing its compliance incentive initiative, we saw it as an excellent opportunity for positive collaboration with the EPA while also reinforcing our compliance programs.”

Most schools and systems participate in the EPA’s self-audit program by having the staff of an outside consulting firm conduct the audit. USG chose a different approach, and partnered with an experienced environmental consulting company to train a pool of environmental health and safety (EHS) personnel from across USG to perform campus audits in conjunction with the outside consultant. This is a significant departure from the typical approach to conducting a self-audit, and offers USG and its individual campuses substantial additional benefits.

A Brief History of the Audit Policy

The EPA Audit Policy, formally called “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations,” offers organizations, including colleges and universities, incentives to voluntarily disclose compliance violations. The incentives include waiving gravity-based penalties if all the conditions of the Audit Policy are met. As described in the Audit Policy, these conditions include:
  • systematic discovery of violations,
  • voluntary discovery of violations,
  • prompt disclosure to the EPA,
  • independent discovery and disclosure,
  • correction and remediation,
  • prevention of recurrence,
  • cooperation by the disclosing entity,
  • repeat violations are ineligible, and
  • certain types of violations are ineligible.

Some colleges and universities enter into specific agreements with the EPA that lay out the terms of the audit and disclosure process, while many chose to use the basic Audit Policy.

“The benefits of the Audit Policy are clear,” said Alex Lehocky, EHS program manager for the USG Board of Regents Office of Real Estate and Facilities. “Many colleges and universities have taken advantage of the Policy and eliminated compliance violations while reducing their exposure to penalties and negative publicity. Both the EPA and the schools that have conducted audits under the Audit Policy believe it’s a very successful strategy.”

The short-term benefits of conducting a self-audit are obvious, but once the audit and disclosure process is over, it can be easy for vigilance to drop and violations to begin to crop up again. Preventing recurrence of the same issues that may be discovered during an audit is a thorny problem, but the USG came up with a creative and sustainable solution.

A New Approach Yields New Benefits
Typically, a college or university that intends to disclose violations under the Audit Policy or a specific agreement with the EPA will hire a consultant to conduct the audit. This assures that the systematic discovery and independent discovery and disclosure requirements of the Audit Policy are met.

Instead of this standard approach, USG created a pool of EHS personnel from its campuses and partnered with environmental consultants Woodard & Curran to provide training, lead the audits, and assist in preparing the self-disclosure reports.

Members of the audit pool attended a three-day intensive training session to review environmental regulations and learned how to conduct environmental audits. The training included a review of applicable regulations and familiarized the auditors with a series of procedures, tools, and checklists used during an audit. Everyone in the pool will participate in a certain number of audits under the leadership of one or two lead auditors from Woodard & Curran, and no one will audit his or her own campus in order to maintain objectivity in audit findings.

The primary benefit of using USG personnel to staff the audits is that every campus in the system will have at least one trained auditor on staff.  Additionally, these auditors can leverage the experience of auditing a sister institution with environmental issues similar to their own campus. As Dr. James Davis, associate vice president for EHS at the Medical College of Georgia campus said, “I could immediately take what I had learned to my team and work on improving our programs well before the audit of my campus was to take place.”

The result is that as audits progress, violations should decrease because each successive campus can apply the lessons learned from previous audits.

It is important to note that the training is time consuming, many of the regulations covered are complex, and the commitment required from both individual auditors and USG should not be downplayed. All told, an estimated 80 USG EHS personnel will put more than 540 days of collective time into training and auditing. But the auditors consider this time well spent. As Meredith Lancaster of Valdosta State University said, “In the training and during audits, I am working closely with my peers from other campuses, sharing observations and ideas, and doing valuable networking. I feel like I have a much larger network I can reach out to for advice and help.”

In addition to these immediate dividends, USG’s investment in its audit program will help create stable and effective compliance programs over the long term. With a group of experienced compliance auditors on staff, USG can implement a system of ongoing check-up audits to ensure that common violations don’t recur and the management systems in place are effective.

USG has put more of its own time and resources into its system-wide program than a traditional approach to conducting self-audits would require, but this investment is already paying off in concrete and intangible ways. These include reducing compliance issues, creating a well-connected network of EHS experts across the system, expanding the overall knowledge of environmental issues and regulatory requirements, and building a partnership with the EPA.

Daniel Winograd
is a regulatory compliance specialist with more than 15 years of experience in environmental law and compliance. He served as environmental council for a major private university and has worked closely with a number of college and university clients on compliance audits and management systems projects. For more information, visit www.woodardcurran.com. 


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