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OVERVIEW
Under the Peer Audit Program, an experienced college peer audit team (i.e. consultant and attorney) trains approximately four (4) college faculty and staff (i.e. peers) from each college on environmental compliance in a group setting over a three-day period at a centrally located college campus. These “peer auditors” then audit colleges (other than their own) under the guidance of a professional auditor. The college saves significant dollars by using peer auditors instead of professional auditors.
This program provides the opportunity for a college or university to take advantage of EPA’s Audit Policy (formerly known as the Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, Notice, 65 F.R. 19618, April 11, 2000). The Audit Policy provides incentives for regulated entities that voluntarily discover (through audits), promptly disclose (within 21 days), and expeditiously correct non-compliance (within 60 days of disclosure). Disclosures meeting the necessary conditions of the policy may receive a partial or complete reduction in financial penalties.
Utilizing the EPA Compliance Incentive Initiative, HRP Associates, Inc., with legal partner Halloran and Sage, LLP, negotiates an Audit Agreement with private colleges and universities and public universities via the association for independent colleges and universities within a respective state. The audit agreement is an effective mechanism for resolving a broad range and number of institution-wide violations discovered during environmental audits pursued under EPA’s Audit Policy. Through the signed Audit Agreement, these colleges and universities are voluntarily cooperating with EPA to conduct audits over the next three (3) years. Furthermore, the audits will be accomplished through the use of peer audit teams, which should help in identification of new opportunities for conservation, as well as providing the potential for sharing of best practices among institutions.
The
peer audit approach has succeeded because peer auditors are able to elicit
unusual cooperation from the faculty and staff of the audited college, it reduces the vulnerability (avoidance of fines and “low inspection
priority”), it provides cost savings to the colleges, it provides opportunities
for positive press (institution being viewed as proactive not reactive), and
it is conducive to fostering a collaborative effort between colleges and
universities. A further benefit is
that trained, experienced peer auditors return to their campuses much better
equipped to monitor environmental compliance at their own schools, ensuring
a safe living and learning environment
The Peer Audit Program utilizes software created by HRP, which is tailored to college and university requirements, training manuals and teaching modules. The software uses developed templates for use at each stage of the process.
PARTICIPATING STATES & COLLEGES/UNIVERSITIES
TESTIMONIALS
WHAT'S NEW