EPAs Audit Policy

For TSCA violations, gravity based penalties are the penalties that the EPA calculates applying a series of policies on penalties applicable to the various types of regulatory violations. These policies are the EPAs Enforcement Response Policies. For an in-depth discussion of the Enforcement Response Policies, see Chapter 14, Penalties and Enforcement 

For a discussion of the application of the Audit Policy as a whole, see Chapter 14, Penalties and Enforcement. 

The list of elements is taken directly from the Audit Policy, 65 Fed. Reg. 19618,19625 (Apr. 

Most EPA Regional offices apply these criteria strictly, and ask probing questions of companies seeking to take advantage of the Audit Policy benefits. In at least one instance the EPA seriously questioned whether a compliance management system could qualify because it did not require feedback to a person who initiated a request for a change to confirm that the change had been made properly. The requirement of a feedback loop is not explicitly stated in the Audit Policy, but is necessitated by it.  

A variety of organizations around the world have devised model management systems. Management systems are usually designed to be dedicated to environmental considerations, or to business processes of the company. The original management systems, even those dedicated to the environmental systems, were not compliance-focused. However, a TSCA compliance 

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