Environmental Audits and Compliance Assessments

Beveridge & Diamond has conducted environmental audits and regulatory compliance assessments at hundreds of facilities, ranging from small plants to large chemical, mining, and manufacturing operations. We assist clients on evaluations ranging in size from one to hundreds of sites. Our work involves virtually every legal and technical aspect of such evaluations, including planning, conducting the audit, reporting audit results, and following up on audit findings.

Our extensive environmental experience makes Beveridge & Diamond uniquely qualified to assist in the environmental audit and assessment process.  We focus on making environmental evaluations useful to our clients, leveraging the results of audits and assessments to improve operations and minimize the risk of enforcement actions and other environmental liabilities. 

The typical services we offer clients include: 

Planning. We help clients determine the scope of the review, such as whether it will cover all aspects of facility operations or only selected aspects. Our extensive knowledge of federal, state, and local environmental requirements allows us to identify applicable standards, including potential future requirements, to ensure the audit evaluates the right issues. We have access to a broad network of environmental consultants who can provide the necessary technical assistance for audits and assessments, and we regularly participate in evaluating consultants and putting together the audit team. We also help clients determine whether to conduct the audit under the protection of the attorney-client privilege.

Auditing. We regularly participate in the audit process, identifying and resolving legal issues that arise as potential deficiencies are identified. Our attorneys have visited hundreds of facilities and know what to look for when participating in an audit. We know which issues are significant and which are not, and we know the potential consequences to the company of what is discovered.

Reporting. We are skilled at writing and reviewing audit reports to ensure that they are legally and factually accurate, and that they appropriately characterize issues identified in the audit. We provide advice on whether identified issues require notification to regulatory authorities. When violations are discovered, we help our clients evaluate the pros and cons of disclosure, including disclosure under federal and state voluntary disclosure policies like the U.S. Environmental Protection Agency's Audit Policy.

Follow-up. One critical aspect of conducting environmental audits is establishing procedures for closing out matters identified in the audit. We help our clients systematically address and document the resolution of every item identified in audit reports, and institute systems to prevent recurrence in the future.

Representative Matters

• Conducting a detailed evaluation of the worldwide environmental management programs of a Fortune 50 company with various consumer good manufacturing subsidiaries. Our evaluation encompassed over 130 facilities located in almost 50 countries. We provided detailed findings and recommendations covering activities at the parent and subsidiary levels, and helped the company implement the recommendations. Our review included detailed regulatory compliance assessments at 25 representative facilities in numerous countries.
• Leading an audit of a nationwide retailer’s hazardous waste and hazardous materials transportation compliance for its reverse distribution system.

• Conducting an environmental, health, and safety compliance audit of a consumer products manufacturing facility in New Jersey.

• Conducting an environmental compliance assessment of a chemical manufacturing facility in New York.

• Designing and implementing an audit program and regulatory compliance audits at four large, independent power production facilities in New Jersey.

• Conducting an environmental compliance audit of a chemical manufacturing facility in Ohio.

• Leading numerous audits of petroleum refineries for Clean Air Act compliance.