Our primary objective is to assist clients in achieving business sustainability by:
- Ensuring regulatory compliance
- Minimizing negative environmental impacts
- Increasing operational efficiencies, and
- Adopting green business practices.
While we are proficient and well-qualified in addressing environmental and safety requirements, we also understand the importance of decreasing applicability to regulations.
Our goal is to partner with client management to identify potential risks, as well as opportunities for improvement.
Our collaborative approach has allowed client organizations to make proactive decisions regarding potential opportunities for improved efficiency, emission reductions, minimizing financial liabilities/risks, Quality, Customer Requirements, Risk Assessment and Loss Prevention, Permitting, Reporting, Planning and Training.
Cornerstone was contracted to audit the regulatory compliance status of a Tier II automotive manufacturer after the departure of the facility’s Environmental, Health and Safety Manager. Although management had been assured compliance was well in hand, our assessment of the manufacturing process confirmed the operation was subject to Federal, State and Local regulations, and that multiple gaps in compliance existed. It was determined the previous employee had not fully understood compliance requirements and, due to lack of familiarity with U.S. regulations, Executive Management had relied on the employee’s assurances regarding compliance status.
Due to the substantial number of gaps in compliance, Cornerstone staff recommended that the client work with legal counsel to pursue the EPA Audit Policy of Self-Disclosure. The self-disclosure enabled the client to report on the gaps voluntarily. Cornerstone worked with the client to ensure a management program was in place going forward. (The EPA Audit Policy of Self-Disclosure generally results in greatly reducing and/or eliminating financial penalties; thus allowing monies spent to be on compliance programs and not fines.)
Lesson Learned: It is prudent to include a third party audit (outside of the company structure) to evaluate compliance on a periodic basis – as sometimes the assurance of an internal employee may not be accurate. Since the gaps in compliance were related to both Federal and State regulations (CAA, CWA, EPCRA), the process of self-disclosure allowed the client to avoid a monetary citation. (Penalties for violations of this nature may be assessed at up to $ 37,500 per day, per violation.)