Facility Audits & Regulatory Inspections
Babst Calland’s representation of clients in various manufacturing sectors at facilities throughout the country often involves providing Environmental (as well as some (health and safety) audit support to clients upon request. The scope of the audit support provided by our Environmental group varies from client to client and is tailor made to fit each particular client’s budget and needs. Our attorneys’ work in this area covers a full spectrum of audit services including, but not limited to:
• establishing the audit privilege;
• managing the distribution of draft and final reports in a confidential and privileged manner;
• reviewing draft audit reports;
• participating as a media or topic-specific team member in internal and external audits;
• and/or conducting external audits ranging from media-specific and/or process-specific reviews to facility-wide multimedia reviews.
The environmental topics typically audited by our attorneys include environmental management, air, water, tanks, waste, Superfund, toxic substances, community right-to-know and release investigation and reporting. Further, as part of the Environmental group’s representation of clients in defense of multimedia inspection efforts, our attorneys have experience conducting pre-inspection compliance audits and providing personnel training, to help minimize potential enforcement exposure. As a result of our audit involvement, we gain a complete understanding of the manufacturing processes at the facilities audited and are then able to provide our clients with more focused compliance advice.
“Conducting audits and implementing recommendations through the audit process is a great way to identify and correct compliance deficiencies on your own watch. Initiating and implementing the audit process under the attorney-client privilege ensures that audit findings will not be used by federal and state regulatory agencies as roadmaps for enforcement. Babst Calland Environmental lawyers have extensive experience in all facets of the audit process, and we serve as valued partners on our clients’ audit program teams.”
– Colleen Grace Donofrio