ASTM-E2107 Standard Practice for Environmental Regulatory Compliance Audits

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Standard Practice for Environmental Regulatory Compliance Audits



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1.1 Purpose—This practice2 identifies minimum requirements for environmental regulatory compliance audits (audits). It also provides information on the terms and procedures associated with audits as practiced in the United States of America (USA) and other jurisdictions subject to the laws thereof. It provides a reference to which interested parties may refer for definition and description of accepted audit terms and procedures.

1.2 Background: 

1.2.1 Awareness of Benefits Associated with Audits—Various benefits have been attributed to audits. These benefits may include a better understanding of the compliance status of a facility or organization, identification of opportunities for environmental management systems improvements, reduction or elimination of potential legal and financial liabilities when implemented as part of a comprehensive compliance management program, better communications and improved relationships with governmental agencies, communities, and other stakeholders, providing information for development of both short-term and long-term environmental expenditures, and education of employees.

1.2.2 Awareness of Risks Associated with Audits—It is also important to recognize that certain risks have been associated with audits. These risks may be managed and controlled by giving thoughtful consideration to the audit process before beginning an audit. These risks may include increased potential legal and financial liabilities for the audited entity if audit findings are not corrected in a timely manner, disclosure of confidential business information or trade secrets, inadvertent admissions against interest because of the wording of audit findings, disclosure of audit findings intended to be kept confidential under audit privilege laws or attorney-client privilege or work product doctrine, and inaccurate audit findings.

1.2.3 Awareness of Legal Issues—A number of important legal issues are associated with audits. Example legal issues include the qualification for one or more evidentiary privileges, the qualification for limited immunity, the protection of trade secrets and confidential information, the application of a number of government policies associated with environmental audits (including federal and state programs that provide incentives for detecting, disclosing, and correcting potential violations through auditing), the form and language of audit reports, the necessity of reporting certain information to the government (either federal, state, or local agencies), the potential liability of auditors, and the importance of promptly addressing issues identified during audits. Prior to initiating and during an audit, interested parties should consider potential legal issues and consult legal counsel or other experts as appropriate.

1.3 Organization—This practice is organized in the following manner:





Referenced Documents




Significance and Use




Auditor Qualifications and Staffing


The Audit Process


Evaluation and Report Preparation




1.4 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

Significance and Use

4.1 Intended Use—This practice is intended for use by parties who wish to perform or direct an audit, or rely upon audit findings or an audit report. Such use includes audits by internal and external auditors.

4.2 Other Audit Criteria—Other audit criteria may be included in the audit scope if specified in the audit plan. Examples include safety and health requirements, and technical, operational, and management requirements.

4.3 Related ASTM Standards—This practice is related to Practice E1527, which addresses CERCLA liability, and Practice E1528, which addresses due diligence for commercial real estate. A number of terms and procedures from these practices are similar to terms and procedures associated with this practice but they may not be the same. Guide E2365 addresses environmental compliance assessment and may be an appropriate tool for some environmental regulatory compliance audits. The user is advised that Guide E2365 is not an all-encompassing compliance assessment tool. Guide E3123 addresses the five types of environmental liabilities named in generally-accepted accounting principles (asset retirement obligations, environmental obligations, commitments, contingencies and guarantees).

4.3.1 Not Interchangeable—Although distantly related to Practices E1527 and E1528, this practice is designed to achieve different results. Therefore, these practices shall not be used interchangeably with, or in place of, this practice.

4.4 Related ISO Guidelines—The International Organization for Standardization (ISO) has developed guidelines addressing environmental auditing. These are ISO 14001-2015 and 19011-2018. A number of terms and procedures from these guidelines may be similar to terms and procedures associated with this practice but they may not be the same. ISO 14001-2015 added several compliance evaluation criteria, including Section 9.1.2 (Evaluation of Compliance) and Section 9.2 (Internal Audits).

4.4.1 Not Interchangeable—Although related to ISO guidelines, this practice is designed for a different purpose. Therefore, these ISO guidelines shall not be used interchangeably with, or in place of, this practice.

4.5 Additional Services—A number of issues may arise as a result of an audit, but are outside the scope of this practice. Such issues include, but are not limited to, development of action plans and cost estimates to address audit findings.

4.6 Conditions—The following conditions shall govern the application of this practice.

4.6.1 Not Exhaustive—A audit shall not constitute an exhaustive review of audited entity compliance with all potentially applicable audit criteria unless explicitly intended and stated as an audit objective in the audit plan.

4.6.2 Level of Review is Variable—The audit scope may vary to meet different audit objectives. For example, the audit scope may include only selected audit criteria, selected period under review, or selected portions of a facility or organization.

4.6.3 Continued Viability of Environmental Audit—An audit completed in accordance with this practice shall be valid for only the period under review. Because audit criteria and audited entity conditions may change over time, it shall not be assumed that an audit report is reliable, or has continued viability, for other than the period under review.

4.6.4 Usage of Prior Audits—Information contained within reports from prior audits should be used only if it has continued viability and if use of that information is appropriate.


environmental audit; environmental compliance; environmental management;

To find similar documents by ASTM Volume:

11.05 (Pesticides and Alternative Control Agents; Environmental Assessment; Hazardous Substances and Oil Spill Response)

To find similar documents by classification:

13.020.10 (Environmental management Including Environmental Management Systems (EMS), certification and audit)

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Publication Date

Jan. 5, 2021

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Page Count

5 pages

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