Thank you to my colleague Bob Melvin for his contributions to the post below. Bob is a partner in the Environmental & Utilities Practice Group whose practice focuses on representing manufacturers with enforcement, compliance, and permitting issues.

Under EPA’s Audit Policy and Small Business Compliance Policy, companies that discover, promptly disclose, and expeditiously correct

Most States, including New York, Connecticut and Massachusetts, and the US EPA have “audit policies”, which are really self-reporting policies, promising small or no fines if a company self-reports a violation that does not otherwise require reporting.  The New York State Department of Environmental Conservation is now proposing a policy to encourage companies to