Cornerstone was contracted to audit regulatory compliance for OEM Tier II automotive manufacturer after the departure of the facility’s environmental, health, and safety manager. Although management had been assured by the EHS manager that compliance was well in hand, the Cornerstone audit confirmed the operation was subject to federal, state, and local regulations, and multiple gaps in compliance existed. It was determined the previous employee had not fully understood compliance requirements and, due to a lack of familiarity with U.S. regulations, executive management had relied on the employee’s assurances regarding compliance status. Due to the substantial number of gaps in compliance, Cornerstone recommended the client work with legal counsel to pursue the EPA audit policy of self-disclosure. The self-disclosure process enabled the client to report on gaps voluntarily. Cornerstone worked to ensure a management program was in place going forward. (The EPA Audit Policy of Self-Disclosure generally results in greatly reducing and/or eliminating financial penalties, thus allowing monies spent to be on compliance programs and not fines.)
Industry
Automotive
Services
  • Regulatory Compliance Assessment

Results/Lessons Learned

It is prudent to include a third-party audit (outside of the company structure) to evaluate compliance on a periodic basis – as sometimes the assurance of an internal employee may not be accurate. Since the gaps in compliance were related to both federal and state regulations (CAA, CWA, EPCRA), the process of self-disclosure allowed the client to avoid a monetary citation.