The U.S. EPA has released a final policy statement on environmental 
self-auditing.  The title of this policy statement is "INCENTIVES FOR 
SELF-POLICING:  Discovery, Disclosure, Correction and Prevention of 
Violations."

IPC will provide a copy of this document to any interested party.  Simply 
contact Star Summerfield (ph 708/509-9700 x347; fax 708/509-9798; email 
[log in to unmask]) and ask for the EPA Audit Policy Statement.  Since the 
document is 20 pages long, IPC will mail it to you unless you absolutely 
need it faxed.

The policy encourages regulated entities to self-audit or "self-police" 
by establishing incentives such as eliminating or reducing civil 
penalties, or not recommending criminal prosecution, under certain 
conditions.  

The first condition is that the violation does not actually harm or 
present imminent and substantial danger to human health or the 
environment.  In addition, the violation must be promptly disclosed and 
expeditiously corrected.  Furthermore, the company must not have repeated 
violations or a pattern of violations.  And the violation may not result 
from conscious or willful disregard for the law, or attempts to conceal 
violations.  

While the EPA will either reduce or eliminate gravity (non-economic 
benefit) penalties under this policy, the EPA will still seek fines to 
offset the economic benefits of violations.  

In addition, the EPA will continue opposing privileged information status 
for audit results, and may require public disclosure of audits as well as 
any written agreements or consent decrees.

For a full copy of the final policy, please contact Star Summerfield at 
IPC.  This issue will also be discussed at the IPC Environmental, Health 
& Safety Committee Meeting and Technical Paper Session on 4-6 March 1996 
in San Jose, CA, during the IPC Printed Circuits Expo.