Re: State Laws Mandating p2

[Graham Noble <gnoble@global.co.za>]

Melissa,

I am greatly interested in your comments on implications of P2 audits
vs. environmental compliance audits and would love a copy of the
Preston, Gates in Seattle presentation on audit priviledge, as an email
attachment or to the following address:
	261 Brook Street
	Brooklyn 0181
	Pretoria
	South Africa
	tel: +27 12 362-0102
	fax: +27 12 362-2607

Many thanks and best regards,
Graham Noble
        
> 
> Tim,
> 
> In the audit privledge arena, I draw the distinction between what a
> facility is likely to find out when they do a P2 audit required by a
> state P2 planning law vs. what they are likely to find out when they
> do a environmental compliance audit or other broad environmental
> audit. A P2 audit is much less likely to identify regulatory
> compliance violations than a typical compliance audit.
> 
> The potential for uncovering violations can be a big disincentive for
> a company to do these environmental compliance audits in the first
> place (discovery of violations may turn subsequent violations into
> "knowing violations" & may trigger reporting requirements).  It's
> important for your audience to realize that P2 audits carry a much
> lower risk of exposure to legal/regulatory liability than a
> compliance audit. Plus, P2 audits have the potential to uncover
> cost/liability savings. So your future-lawyers should not hesitate
> to recommend a P2 audit, whereas they will want to be well prepared
> before recommending a compliance audit (i.e., they should make sure
> that the resources are in place to quickly address any problems
> that are found).
> 
> Some folks at Preston, Gates in Seattle did a good presentation on the
> topic of audit priviledge a while back -- contact me off list if you
> want a copy.
> 
> Regards,
> Melissa
> ...................................................
> Melissa Malkin, J.D. -- but don't hassle me about it, OK?
>      Pollution Prevention Program
>      Research Triangle Institute
>      POB 12194. Research Triangle Park, N.C. 27709-2194
>      (ph)   919-541-6154                        (fax)   919-541-7155
>       http://www.rti.org/units/ese/pp.html
> ....................................................