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University self audit searches for EPA violations

Amy Peterson

Issue date: 7/22/05 Section: News
The University's facilities are undergoing an inspection by the United States Environmental Protection Agency which started July 11 and will continue through July 29.

The self audit is meant to determine whether the University's facilities are in compliance with environmental regulations and to correct any violations. The goal of these inspections is to prove that the facilities are in compliance with the EPA's regulations. For facilities that are non-compliant, EPA will create a plan that will help them lead to becoming compliant. Once compliance is achieved, facilities can then receive the benefits of the EPA's policy entitled "Incentives for Self-Policing: Discovery, Disclosure, Correction, and Prevention of Violations."

These benefits include "waiving or reducing gravity-based civil penalties, declining to recommend criminal prosecution for regulated entities that self-police, and refraining from routine requests for audits," as stated in the policy. Gravity-based refers to the part of the penalty above the portion that represents the economic gain from noncompliance. The policy also reiterates the EPA's practice of not requesting copies of voluntary audit reports to trigger potential federal investigations. Such benefits are allowed because the goal of this policy is to enhance the protection of people as well as the environment.

This new policy contains nine conditions that must be met by regulated entities. If a violation of EPA regulations is discovered and all of the conditions are met, the entity will be eligible for complete mitigation of any gravity-based penalties assessed. Entities that do not meet the first condition of systematic discovery of violations, but meet the remaining eight conditions will be eligible for 75% mitigation of gravity-based penalties.

"The University had planned to initiate a self-audit anyway," Senior Associate Vice President of Health Sciences and Campus Operations Frank Pizzulo said. "The self-audit and -disclosure program offered by the EPA was thought to be an ideal way for Drexel to undertake this comprehensive, university-wide assessment, since it provided a ready-made structure for doing so."
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