Attendees will gain practical and useful knowledge on EPA’s Audit Policy and when the Policy can and/or should be used to assist in achieving and maintaining compliance. The session will introduce or refresh attendees on the Policy’s benefits when they voluntarily discover and correct violations of federal environmental laws. These benefits include a 100% reduction of gravity-based civil penalties, the potential for full reduction of all penalties, and a recommendation for no criminal prosecution. Attendees will learn about the nine prerequisites that must be met to qualify for these benefits, and how the focus of these nine factors are on the systematic, voluntary, and independent discovery of violations, followed by reporting and correction of those violations.
Tuesday, September 10, 3:00-3:45 PM
Presenter
Ray Coss, Esq.
Ray Coss is a Consulting Counsel with Latitude Legal, a global flexible legal staffing company. He is a seasoned attorney with over 35 years of experience, most of which was as an EHS in-house counsel at four Fortune 500 companies.
After college, Ray served in the U.S. Marine Corps, first as a Bombardier/Navigator in the A-6 Intruder, an all-weather attack jet aircraft. After attending law school, he was a criminal prosecutor and civil law advisor. Following active duty in the Marines, Ray attended George Washington University and received a Master of Law (LLM) degree in Environmental Law. During his time at GW, Ray was a graduate law intern at U.S. EPA (Toxics Litigation Division) and U.S. DOJ (Environment and Natural Resources Division).
Ray has experience with all matters EHS, mostly in manufacturing and big box home improvement retail. He enjoys getting out on the manufacturing floor to ‘go and see’ and talk with the operators who are actually over the processes. In 2008, Ray retired from the U.S. Marine Corps Reserve as a Colonel. Ray retired from Nissan North America, Inc. in 2018.
