SMG routinely works with clients to maintain and improve environmental compliance. In cases of potential non-compliance, we work to remedy the issue and work to eliminate or minimize penalties. One tool we evaluate for mitigating potential penalties is voluntary self-disclosure. This option is available with EPA through use of their Audit Policy or Small Business Compliance Policy if qualifying conditions are met. A similar state option is available through the DEP via statute KRS 224.1-040. The Kentucky self-audit privileges are explained in the February 3, 2013 article in Naturally Connected.
EPA held webinars this month on eDisclosure, the Agency’s Plan to Modernize the Implementation of the Audit Policy and the Small Business Compliance Policy. A summary of changes expected this fall is available on the EPA website at: http://www2.epa.gov/compliance/epas-audit-policy. A copy of the presentation is available for download. Additionally, this information sheet provides a nice summary.
Non-compliance is risky. In addition to the health and physical risks it may present, it can result in massive penalties and can be a public relations nightmare. SMG can help. Contact me for more information at 502-587-6482 x211 or pattym@smithmanage.com.