The Business Council of New York State invited D&B Senior Vice President Rich Walka to present at its October 2011 Industry-Environment Conference. The suggested topic…….a review of the USEPA’s Self-Audit Policy. Coincidently, Rich and D&B Senior Associate Ellen R. DeOrsay had co-authored and published a 2 part paper in the journal , Environmental Law in New York entitled, “The U.S. EPA Region 2 Facility Audit Agreement: Opportunity or Albatross? , in its August and September 2007 edition, respectively. Essentially, the paper reviewed the genesis of the entire environmental audit agreement process, the targeting of specific “market sectors “for enforcement at the federal level and reflected on and shared the direct situations that Rich and Ellen experienced with their clients who elected to participate in the program. Utilizing the 2 part series as the basis for the Business Council presentation, the co-authors decided to update some of the material in the article and invite one of their clients to participate in the presentation as well. The effort resulted in the delivery of two presentations dealing with the federal Facility Audit Agreement process, each presenting a different perspective. The presentations were entitled, “The USEPA’s Self-policing/Audit Policy—A Consultant’s Perspective” and “The USEPA’s Self-policing/Audit Policy—An Industry Perspective”.
Retrospectively, the presentations did provide impetus for the New York State Department of Environmental Conservation to initiate discussion and consideration of a comparable policy at the State level.