Applying The EPA Audit Policy To New Owners

Law360, New York (December 15, 2008, 12:00 AM EST) -- The U.S. Environmental Protection Agency is putting forth an Interim Approach for applying its incentive program for self-disclosure of environmental regulatory violations to owners of recently acquired facilities.

While the EPA should be applauded for the expansion of its progressive approach to achieving positive environmental outcomes, the limitations of the Interim Approach suggest that the EPA missed an opportunity to more fully promote compliance with environmental requirements.

The EPA should consider a broader application of the underlying policy, and focus more on providing new owners the...
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