Multi-Facility Audit and Self Disclosure Under EPA Audit Policy

Client:	Financial Services Company
Representation:	Compliance Auditing and Reporting
Date:	2007 to present
Locations:	Nationwide

Summary:

In 2007, Schiff Hardin advised a client in connection with its discovery of several years of apparent non-compliance with Emergency Planning and Community Right-to-Know Act (EPCRA) reporting and other reporting and permitting requirements at one of its data centers. The violations related to the uninterrupted backup power system at the data center.

Suspecting that more than 40 other facilities might have similar issues, the client retained Schiff Hardin for assistance in conducting a multi-facility audit. We assisted the client in structuring the audit and negotiated an agreement with U.S. Environmental Protection Agency (EPA) allowing for the audit and self-disclosure of violations under the EPA's audit policy.