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Title: Self Disclosure (SEC/EPA)
Author: William A. Danchuk
Source: American Gas Association 1998
Year Published: 1998
Abstract: The Federal EPA Self-Disclosure Policy, first published as an interim policy on April 3, 1995, was in direct response to the promulgation of auditing exemptions and privileges developed by approximately one half of the states in this country. These state policies offered full or partial privilege for selfauditing and, in several cases, full exemption from civil and even criminal liability under state law for violations discovered through audits. To this day, EPA is not happy about state involvement in the auditing privilege arena and, as Ill explain shortly, has threatened to target companies who are exempted under state law for inspections based on the specifics of the case.

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