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Compliance Audits, Recordkeeping, and Self-Audit Programs

Most regulatory agencies have adopted a policy to support companies, which audit their own facilities to correct any regulatory violations in a timely manner. Depending on the circumstances of the case, penalties sought for a violation discovered through self-auditing and promptly reported to the District are significantly reduced or when appropriate, waived in order to encourage all facilities to implement an effective self-auditing program.

To determine whether a company is eligible for a reduced or waived penalty, the regulatory agencies use the following criteria:

The violation must be discovered by the facility without any participation by the regulatory agency

The violation must be reported voluntarily by the facility, i.e. without any requirement to do so by law, regulation, permit or agreement

The violation must be reported promptly by the facility to the appropriate agency as soon as possible after discovery

The violation must be corrected promptly and effectively by the facility to reduce or eliminate all emissions and to prevent recurrence of the violation

AQMS recommends preparation of an Air Audit Compliance Plan to provide a structured approach for achieving short and long-term objectives for air compliance and pollution prevention. This includes an assessment of current program operation through an internal “self-audit” to establish facility’s level of compliance and non-compliance. The assessment includes any issues or problems relating to establishing full compliance (if areas of noncompliance exist) and maintaining compliance in the future. Environmental managers can use the “self audit” program to define for senior management, customers, regulators, and the general public their proactive approach toward environmental compliance and pollution prevention. The compliance plan also supports program budgeting activities necessary to address existing requirements, evaluate the impact of anticipated regulations, and fund additional initiatives that will provide long-term benefits to the organization.

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