Environmental compliance audit checklist

Facilities must follow applicable local, state, and federal standards and regulations regarding environmental compliance. The Environmental Protection Agency (EPA) regulates environmental compliance by monitoring and performing inspections.

To be prepared for the EPA, employers should understand what environmental regulations are applicable and what type of records the EPA will look for if they perform an inspection.

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How are environmental regulations enforced?

Below are the primary ways that regulatory agencies enforce environmental requirements in the United States.

Compliance monitoring

Compliance monitoring is one of the critical components the EPA uses to ensure that employers obey environmental laws and regulations. It encompasses all regulatory agency activities performed to determine whether facilities or groups of facilities comply with applicable laws.

In general, compliance monitoring includes:

Formulation and implementation of compliance monitoring strategies
Onsite compliance monitoring: inspections, evaluations, and investigations, including review of permits, data, and other documentation.
Offsite compliance monitoring: data collection, review, reporting, program coordination, oversight, and support
Inspector training, credentialing, and support

Inspections

Inspections are an integral part of the EPA’s compliance monitoring programs. They are an essential tool for officially assessing compliance with environmental regulations and requirements. The EPA and its regulatory partners conduct compliance inspections under the majority of statutory and regulatory program authorities.

Inspections are visits to a facility or site to gather information to determine whether the facility complies with local, state, or federal laws. Inspections generally include pre-inspection activities such as obtaining general site information before entering the facility or site. Other activities that may be conducted during the onsite visit include:

interviewing facility or site representatives
reviewing records and reports
taking photographs
collecting samples
observing facility or site operations

Inspections are usually conducted by focusing on a single program, such as the Clean Air Act (CAA), but can be conducted for more than one media program. Inspections can also be conducted to address a specific environmental problem specific to a facility or industry sector. For example, CAA evaluations can be either a Full Compliance Evaluation (FCE) or a Partial Compliance Evaluation (PCE).

An FCE is a comprehensive evaluation of the facility’s compliance status and looks for all regulated pollutants at all regulated emission units. An FCE may be accomplished through a series of PCEs, which focus on a subset of pollutants, requirements, or emission units.

Compliance audits

How can companies make sure that their processes are complying and meet inspection guidelines? One way is to perform regular audits and record reviews of the facility that focus on the environmental regulations applicable to that facility. Employers should use the information below as guidance to prepare for an EPA inspection by ensuring records are documented, and facility inspections are performed.

Detailed regulatory checklists for compliance include the:

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
Clean Water Act (CWA)
Emergency Planning and Community Right-to-Know Act (EPCRA)
Resource Conservation and Recovery Act (RCRA)
Safe Drinking Water Act (SDWA)
Toxic Substances Control Act (TSCA).

Some or all of these checklists could apply to a given facility or group of facilities.