College Peer Audit




In the late 1990s, EPA began an enforcement initiative against colleges and universities where fines for multimedia inspections averaged approximately $500,000 per college. The solution developed by HRP was a “peer environmental audit” program, which allowed each college to self-audit using personnel from peer audit institutions trained on environmental regulations and armed with auditing software. Nearly 300 colleges and universities have now participated in HRP’s Peer Audit Program. The program has been successfully completed in AL, FL, GA, IN, KS, NC, MI, NJ and TN (EPA Region 2,4,5,7), and is now expanding to AR and TX (EPA Region 6).

How the Peer Audit Program Works
  • Step 1 - Join Program: Participating schools enter the program through the local State association of colleges and universities. HRP’s legal partner negotiates a peer-audit agreement with EPA.
  • Step 2 - Training: HRP trains your selected peer-auditors on the applicable environmental regulations.
  • Step 3 - Audit and Audit Report: HRP’s professional staff oversees your peer auditors to complete on campus audits. HRP prepares an audit report for you detailing the violations identified.
  • Step 4 - Disclosure to EPA and Corrective Action: With legal assistance, each college or university discloses the violations to EPA, and promptly corrects the violations. HRP can assist you in correcting compliance violations as requested.
  • Step 5 - Final Compliance Report (FCR): Upon completion of corrective actions and in consultation with the college or university, HRP produces a FCR, detailing compliance with the conditions of the audit agreement. The EPA office provides you with a Notice of Determination, which outlines the school’s compliance with the Audit Policy and Agreement and disclosed violations and grants the appropriate penalty waivers.
  • Step 6 - Development of Environmental Management Systems (EMS): HRP conducts a four-part workshop on creating an EMS, and assists in individual program development. EMS is an essential part of the agreement and provides you with a system to assist with future compliance, continuous improvement, and future sustainability.


“I just wanted to inform you that we had a surprise inspection from the DEP last month. We took no hits, no fines!  I attribute this in large part to the efforts of your organization, yourself and AICUNJ. Without the self-audit, the lessons we learned from it and the continuous self-improvement mind-set we gained from it, I don’t believe that this inspection would have been as positive an experience as it was.  Thank you!” Ray Flash, CPO, MOUS, MCP, IC3, Service Response Manager, Centenary College

Under HRP’s peer-audit program, many colleges and universities have avoided hundreds of thousands of dollars in fines while achieving environmental compliance throughout their campuses. Please see the National Program of Environmental Peer Audit Statistics for further details.