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We were recently told that the DEQ Assessment that was conducted does not count as an extensive audit of our Legal compliance obligations and we can either hire a company to do a compliance obligation audit or we can do it ourselves. We are not familiar with what all needs to be done. Does anyone have any recommendations on a company that would this for us in the St. Clair Michigan area? Has anyone handled this internally? We had a quote from one company at $3500. We are thinking this is a bit much considering the size and scope of our operation.
My recommendation would be to go the self-assessment route. If you are like us you have very few significant environmental aspects and it is not value added to pay for a lot of outside audits and assessments. So, with the DEQ Assessment that should cover the regulation compliance for the state of Michigan. You will need to check with your local city and county to see if they have any requirements that would not be covered under the state. More than likely they wont know what you are talking about and refer you to the state if it is like most small municipalities, but they might. Lastly, you will need to review the applicable CFR Title 40 Federal Requirements and identify any that would be applicable to you. These can be found on-line. There probably will not be many, ie. mercury in flourescent bulbs, used hydraulic oil from machines, freon used by your HVAC contractor, etc. You will just need to add all these together on a audit checklist (local, county, your DEQ assessment, and Federal) and spell out what you are doing to comply and give yourself a pass/fail. Obviously any fails will require internal corrective action.