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Environmental Self-Auditing: Setting the Proper Incentives for Discovery and Correction of Environmental Harm


  • Pfaff, Alexander S P
  • Sanchirico, Chris William


Many firms conduct "environmental audits" to test compliance with a complex array of environmental regulations. Commentators suggest. however, that self-auditing is not as common as it should be, because firms fear that what they find will be used against them. This article analyzes self-auditing as a two-tiered incentive problem involving incentives both to test for and to effect compliance. After demonstrating the inadequacy of conventional remedies, we show that incentives can be properly aligned by conditioning fines on firms' investigative effort. In practice, however, the regulator may not be able to observe such effort. Accordingly, we propose and evaluate the use of three observable proxies for self-investigation: the manner in which the regulator detected the violation: the firm's own disclosure of violations; and the firm's observed corrective actions. Each method has its own efficiency benefits and informational requirements, and each is distinct from EPA's current audit policy. Copyright 2000 by Oxford University Press.

Suggested Citation

  • Pfaff, Alexander S P & Sanchirico, Chris William, 2000. "Environmental Self-Auditing: Setting the Proper Incentives for Discovery and Correction of Environmental Harm," Journal of Law, Economics, and Organization, Oxford University Press, vol. 16(1), pages 189-208, April.
  • Handle: RePEc:oup:jleorg:v:16:y:2000:i:1:p:189-208

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    References listed on IDEAS

    1. Olson, Mary, 1996. "Substitution in Regulatory Agencies: FDA Enforcement Alternatives," Journal of Law, Economics, and Organization, Oxford University Press, vol. 12(2), pages 376-407, October.
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    4. Olson, Mary K, 1995. "Regulatory Agency Discretion among Competing Industries: Inside the FDA," Journal of Law, Economics, and Organization, Oxford University Press, vol. 11(2), pages 379-405, October.
    5. Weingast, Barry R & Moran, Mark J, 1983. "Bureaucratic Discretion or Congressional Control? Regulatory Policymaking by the Federal Trade Commission," Journal of Political Economy, University of Chicago Press, vol. 91(5), pages 765-800, October.
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    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.

    Cited by:

    1. Friesen, Lana, 2006. "The social welfare implications of industry self-auditing," Journal of Environmental Economics and Management, Elsevier, vol. 51(3), pages 280-294, May.
    2. Guerrero, Santiago & Innes, Robert, 2008. "Statutory Rewards to Environmental Self-Auditing: Do They Reduce Pollution and Save Regulatory Costs? Evidence from a Cross-State Panel," 2008 Annual Meeting, July 27-29, 2008, Orlando, Florida 6204, American Agricultural Economics Association (New Name 2008: Agricultural and Applied Economics Association).
    3. James J. Murphy & John K. Stranlund, 2005. "An Investigation of Voluntary Discovery and Disclosure of Environmental Violations Using Laboratory Experiments," Working Papers 2005-7, University of Massachusetts Amherst, Department of Resource Economics.
    4. Paul Calcott, 2010. "Mandated self-regulation: the danger of cosmetic compliance," Journal of Regulatory Economics, Springer, vol. 38(2), pages 167-179, October.
    5. Michael W. Toffel & Jodi L. Short, 2011. "Coming Clean and Cleaning Up: Does Voluntary Self-Reporting Indicate Effective Self-Policing?," Journal of Law and Economics, University of Chicago Press, vol. 54(3), pages 609-649.
    6. Mary Evans & Lirong Liu & Sarah Stafford, 2011. "Do environmental audits improve long-term compliance? Evidence from manufacturing facilities in Michigan," Journal of Regulatory Economics, Springer, vol. 40(3), pages 279-302, December.
    7. Earnhart, Dietrich & Harrington, Donna Ramirez, 2014. "Effect of audits on the extent of compliance with wastewater discharge limits," Journal of Environmental Economics and Management, Elsevier, vol. 68(2), pages 243-261.
    8. Carmen Arguedas, 2013. "Pollution standards, technology investment and fines for non-compliance," Journal of Regulatory Economics, Springer, vol. 44(2), pages 156-176, October.
    9. Alexander Pfaff & Chris William Sanchirico, 2004. "Big field, small potatoes: An empirical assessment of EPA's self-audit policy," Journal of Policy Analysis and Management, John Wiley & Sons, Ltd., vol. 23(3), pages 415-432.
    10. Darnall, Nicole & Seol, Inshik & Sarkis, Joseph, 2009. "Perceived stakeholder influences and organizations' use of environmental audits," Accounting, Organizations and Society, Elsevier, vol. 34(2), pages 170-187, February.
    11. Etienne, Julien, 2010. "Self-reporting untoward events to external controllers: accounting for reporting failure by a top tier chemical plant," LSE Research Online Documents on Economics 36546, London School of Economics and Political Science, LSE Library.
    12. Michael W. Toffel, 2008. "Coerced Confessions: Self-Policing in the Shadow of the Regulator," Journal of Law, Economics, and Organization, Oxford University Press, vol. 24(1), pages 45-71, May.
    13. Motta, Alberto & Burlando, Alfredo, 2007. "Self reporting reduces corruption in law enforcement," MPRA Paper 5332, University Library of Munich, Germany, revised 23 Jun 2007.
    14. Evans, Mary F. & Liu, Lirong & Stafford, Sarah L., 2015. "Standardization and the impacts of voluntary program participation: Evidence from environmental auditing," International Review of Law and Economics, Elsevier, vol. 43(C), pages 10-21.
    15. Marcel Boyer & Donatella Porrini, 2004. "Modelling the choice between regulation and liability in terms of social welfare," Canadian Journal of Economics, Canadian Economics Association, vol. 37(3), pages 590-612, August.
    16. Bhole, Bharat & Wagner, Jeffrey, 2008. "The joint use of regulation and strict liability with multidimensional care and uncertain conviction," International Review of Law and Economics, Elsevier, vol. 28(2), pages 123-132, June.
    17. repec:kap:regeco:v:52:y:2017:i:2:d:10.1007_s11149-017-9329-7 is not listed on IDEAS
    18. Anup Malani & Ramanan Laxminarayan, 2011. "Incentives for Reporting Infectious Disease Outbreaks," Journal of Human Resources, University of Wisconsin Press, vol. 46(1), pages 176-202.

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