Environmental Management and Audits

The capture of accurate and timely performance data is critical to environmental compliance, reporting and certification. In order to ensure that the data is captured properly for the intended purpose, Schiff Hardin finds that a well-crafted audit program is invaluable. In addition, an effective audit program can discover more serious problems in facility operations, allowing the company to self-report and receive the penalty leniency provided to self-reporters.

An audit looks at a sampling of issues at a single facility, within a particular program, or for a particular type of liability and gauges the level of the company's performance.

Periodic Compliance Audits

A periodic compliance audit can be performed with dedicated in-house staff, operations staff or by outside vendors. The purpose is established by the company to meet the company's business objectives. Our lawyers can assist you in:

Establishing goals of audit programs
Establishing the audit program as a key measure of management performance
Training top management about the value and importance of an audit program
Establishing corrective action priorities
Reviewing audit findings
Developing plans to address systemic non-compliance
Overseeing appropriate implementation to take advantage of state and federal "audit privileges"

Public Disclosure Information

Audits are invaluable in discovering data for reporting to the SEC, for ISO certification programs, and the like. Schiff Hardin can assist in developing an environmental management system that will capture information necessary for public disclosures.

Permit-required or Program-required Audits

From time to time, because of allegations of wrong-doing or to comply with existing laws or enforcement requirements, companies must rigorously and independently test the performance of facility staff. Schiff lawyers have had experience with the following:

Review performance of and calibration procedures for pollution control equipment
Investigation of and reporting of irregularities or non-compliance identified by operations or outside complaints
Restating of data to regulatory agencies, if necessary
Auditing performance pursuant to an enforceable order with a regulatory agency
Auditing compliance with permit provisions or operational changes after issuance of a Notice of Violation
Auditing and reporting of progress for required Supplemental Environmental Projects