EPA’s Audit Policy eDisclosure: Electronic Self-Reporting for Environmental Violations

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Reporting uner EPA’s audit policy, which has provided relief from gravity-based penalties to those who self-report, is about to become much easier. This fall, EPA expects to launch a centralized web-based “eDisclosure” portal that will make self-disclosure just a mouse click away. The requirements of the audit policy remain unchanged (e.g., violations must be disclosed within 21 days, corrected within 60 days of discovery, etc.) but reporting will be done electronically. In addition, for certain Emergency Planning and Community Right-to-Know (EPCRA) violations that are self-reported, EPA will issue an electronic Notice of Determination (eNOD) and resolve the violations with no assessment of civil penalties.

For more information on EPA’s audit policy and on the eDisclosure system, go to http://www2.epa.gov/compliance/epas-audit-policy.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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