Compliance Audits
The Payne Firm is often contacted by companies who have discovered environmental exposure of some kind or have an impetus – such as in merger and acquisition situations – to find out, quickly, if any exist. While the Firm excels at this type of “acute” consulting, it doesn’t always have to be that way.
 
Prudent business management dictates that a company should always think one – or two or three – steps ahead. This holds true in the management of its environmental responsibilities as well. And The Payne Firm can help, via “environmental compliance and safety audits.”
 
The purpose of such audits is to evaluate environmental and safety exposures and risks before they become acute. They allow a company to be proactive in their approach to environmental and safety issues, eliminating any “surprises” and saving valuable time and money.
 
The Payne Firm’s multi-step process begins with a review to assess current environmental and safety compliance, which determines the scope of the audit. Next, the Firm conducts a brief review of the company’s site history through previous environmental reports, if they are available, and a search of regulatory databases such as the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) and National Priorities List (NPL). These database searches identify any regulated sites located near the property being audited, as such sites could impact it.
 
The third step in the audit is on-site reconnaissance and file review, including a questionnaire or a series of interviews to gather information on current compliance status. The questionnaire/interviews will cover issues related to compliance with the Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), Superfund Amendments and Reauthorization Act (SARA), Occupational Safety and Health Act (OSHA), and other relevant state and federal programs. Specifically, we will investigate solid, liquid and hazardous waste disposal, storm water, wastewater, permitting, record keeping, environmental emergency plans, Form R reports, OSHA 200 log, hazard communication, confined space entry, respirator protection, fall protection, machine guarding, lockout/tagout, and other environmental and safety issues.
 
When the research is complete, The Payne Firm will prepare a confidential summary report. The report will interpret findings, identify appropriate approaches to manage any issues that are discovered, and provide technical guidance on strategies for negotiating with regulatory agencies, if necessary. The report may be prepared as a summary document or in the form of tables and spreadsheets that serve as a model for compliance improvements. Once the improvements are made the summary report may be prepared.
 
Recognizing that budget or personnel constraints may prevent some companies from engaging in a comprehensive environmental and safety audit, The Payne Firm has created an innovative program called the Compliance Partnership. This Partnership allows companies to draw on The Payne Firm’s environmental and safety expertise in an on-going but cost-effective manner. It is designed to minimize the company’s exposure in an economical, logical and effective manner.