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Mailed to All College and University Presidents in Region 2
December 1999

Re: Voluntary Discovery and Disclosure of Potential Environmental Violations

Greetings:

The U.S. Environmental Protection Agency (EPA) Region 2 is planning to conduct inspections of colleges and universities within our region (New York, New Jersey, Puerto Rico, & U.S. Virgin Islands) during the upcoming year to determine their compliance with hazardous waste and other environmental regulations.

It has come to our attention that some colleges and universities do not fully comply with environmental regulations. If inspections determine non-compliance, formal enforcement action with monetary penalties against significant violators is possible.

Such actions can be mitigated, however. This may be achieved through EPA's Audit Policy, "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, Notice, 60 F.R. 66706, December 22, 1995." The Audit Policy has several important goals including encouraging greater compliance with the laws and regulations which protect human health and the environment through self-policing, discovery, disclosure, correction and prevention. If certain criteria are met, reductions in gravity-based penalties of up to 75% (100% in some cases) resulting from EPA enforcement of violations discovered and disclosed by your institution under the Audit Policy are possible. A copy of the Audit Policy is attached. The Audit Policy, along with some interpretive guidance, is also available on the Internet at http://es.epa.gov/oeca/ore/apolguid.html.

I urge you to take advantage of the Audit Policy to identify any violations and to voluntarily correct them prior to our inspecting colleges and universities in the spring of the year 2000. If violations that warrant formal enforcement are discovered during an EPA inspection of your institution prior to your self-disclosing them, penalty reductions possible through the Audit Policy will not apply.

If you have questions, need more information, or would like to participate in an informational meeting, please contact John Wilk, Self-Disclosure Policy Coordinator, at (212) 637-3918. Please also see the attached fact sheet.

Any voluntary compliance evaluations undertaken by your institution in response to this letter should focus on compliance with hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA) as well as other environmental regulations that apply.

Sincerely yours,

George Pavlou, Director
Division of Enforcement and Compliance Assistance

 

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