Exploring Leading Practices for Environmental Liabilities

8/13/2019 Exploring Leading Practices for Environmental Liabilities

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Deloitte & Touche LLP

July 2011

Auditing ManagementEstimates:Exploring Leading

Practices forEnvironmentalLiabilities



Auditing Management Estimates

Introduction

Performing and documenting our testing of management estimates and

judgments has historically been, and continues to be, the area with the

highest rate of findings in internal and external inspections. When auditing

accounting estimates the primary objective of the auditor is to obtain

sufficient appropriate audit evidence to provide reasonable assurance that

the estimates are reasonable in the circumstances.

The underlying theme in the inspection

findings is that often we are not obtaining

sufficient appropriate audit evidence.

The foundation of this practice aid was a

review of internal and external inspection

findings. Although the findings span a

number of different audit areas, and

occurred along the various elements of

the audit process, our significant findings

have predominantly been associated

with substantive testing when we

evaluated and tested the process used by

management to develop the estimate.

This practice aid was developed to assist professionals with gaining an

understanding of the common pitfalls identified related to our audit work

on management estimates, and provide further considerations to assist

engagement teams with developing additional procedures to remediate

these findings.

This practice aid provides professionals with:

• A workow that depicts the key elements of the audit process for

management estimates, which identifies common pitfalls along

that process

• A discussion about environmental liabilities that includes:

– Audit considerations for engagement leadership, primary reviewers,

and engagement quality control reviewers that often will be

appropriate in the context of the estimate

– Abbreviated hypothetical examples that denote audit considerations

for staff practitioners

As discussed above, our significant

findings have predominantly been

associated with substantive testing when

we evaluated and tested the process

used by management in developing the

estimate; thus, the focus of this practice

aid is on substantive testing.

It does not address testing the

operating effectiveness of internal

controls over financial reporting. It

also does not address the substantive

audit procedures that we perform

when we use other approaches to

auditing management’s estimates (i.e.,

developing an independent expectation of the estimate to corroborate the

reasonableness of management’s estimate, or reviewing subsequent events

or transactions occurring prior to the date of the auditor’s report).

Identify circumstances

that require estimates

Understand management’s

process (consider risk of

material misstatement)

Test management’s

process

Develop an

independentexpectation

Review subsequent

events or transactions

Analyze evidence

obtained and conclude

Contemporaneously

document

2

Note: As described in U.S. AAM P020.15, certain management estimates are considered to be significant matters. Each management estimate identified as a significant matter is

required to be described in our audit planning and summary memorandums in a manner that facilitates a thorough understanding of the significant matter [U.S. AAM 2010.02a, U.S.

AAM 7500.02a]. Furthermore, the engagement partner is required to perform a primary review of the audit documentation related to all significant matters and discuss such matters

with the engagement quality control reviewer [U.S. AAM P040.13a, U.S. AAM G240.02].

Our testing of management estimates is the single

greatest source of PCAOB findings

Common pitfalls include:

• Failing to evaluate management’s assumptions

or challenge management’s explanations for

reasonableness

• Failing to test underlying data used in developingestimates

• Failing to perform retrospective reviews

This practice aid was designed to help you avoid

these pitfalls



Identify circumstances

that require estimates

3

Understand management’s

process (consider risk of

material misstatement)

Test management’s

process

Analyze evidence

obtained and conclude

Contemporaneously

document

Understand the entity, its environment, and management’s process as part

of our risk assessment

Consider alternative models/methodologies

Consider controls around accumulation of reliable data

Consider controls at service organizations and end user controls

Consider if management uses or ought to use a specialist

Perform retrospective review

Consider whether there has been a change or ought to have been a

change in the process

Test controls at appropriate level of precision

Test completeness, accuracy, and relevance of any underlying data

Understand specialists’ qualifications, methodologies, and assumptions

Concentrate on key factors and assumptions

Consider alternative assumptions

Review estimates for indicators of bias

Obtain audit evidence to provide reasonable assurance that the estimate i

appropriate in the circumstances

Consider alternative factors or assumptions and conclude as to why the

factors and assumptions used were most appropriate

Consider all positive, negative, and contradictory evidence

� Failure to consider all available evidence

� Leverage management’s conclusion instead of challenging it

� Failure to obtain sufficient persuasive evidence to overcome negative or

contradictory information

Include relevant professional literature, GAAP, and GAAS, when

documenting the conclusion

Document consultations with Firm specialists and subject matter experts

Document considerations of contradictory or inconsistent audit evidence

Document challenges that were raised and alternative positions and

assumptions considered

� Documentation fails to demonstrate the exercise of professional skepticism

� Failure to carry forward documentation or evidence

Auditing Management Estimates —Workflow

Evaluating assumptions

i n c l u d e s

Testingunderlying

data

Evaluatingfor bias

i n c l u d e s

Using aspecialist

Testing operatingeffectiveness ofinternal controls

i n c

l u d e s

i n c

l u d e s

i n c

l u d e s

Test management’sprocess

Retrospective

review

i n c l u d e s

Model/ Methodology

Assumptions &Uncertainty

Changes fromprior year

i n c l u d e s

i n c l u d e s

Using aspecialist

Internalcontrol: D&I

i n c

l u d e s

i n c

l u d e s

i n c

l u d e s

Understand management’sprocess (consider risk ofmaterial misstatement)

Develop an

independent

expectation

Review subsequent

events or transactions

The following is a workflow depicting the key elements of the audit process for testing management estimates. The s indicate keyconsiderations for each of the elements while the �s indicate common pitfalls.



4

� Failure to obtain an understanding of management’s process and

methodologies

� Controls identified and tested were not sufficiently precise to address the

assertion

� Failure to identify controls at service organizations in addition to end user

controls

� Failure to alter nature, timing, and extent from prior years

� Failure to challenge management’s ability to accurately estimate by

performing retrospective review

� Failure to perform sensitivity analysis to identify the significant assumptions

� Failure to identify alternative assumptions

� Failure to challenge whether the process or methodology remained

appropriate in the current year

� Failure to test underlying data for completeness and accuracy

� Tested controls related to data integrity are not sufficiently precise

� Failure to assess the impact of control deficiencies on related substantive

procedures

� Failure to identify or address control deficiencies noted in SAS 70

� Tested controls do not address relevant assertions

� Failure to adequately understand specialist’s methodology and/or

assumptions

� Failure to reconcile or understand differences between specialist’s

calculation and the amount recorded by management� Failure to adequately address and document matters raised by internal

specialists

� Documentation includes “Per discussion with management” without

corroboration through source documents, reports, etc.

� Management assumptions are not challenged with external data

� Failure to consider whether differences between estimates best supported

by the audit evidence and the estimates included in the financial

statements, even if they are individually reasonable, indicate a possible bias

on the part of management

Understanding and TestingManagement’s Process —

Common Pitfalls A

B

C

D

E



This material is split into two parts, a Reviewer Considerations

section and a Staff Practitioner’s Examples section.

In the Reviewer Considerations section you will find:

• A description of the estimate

• A list of signicant assumptions that often are applicable

to the respective estimate

• A list of factors that often inuence the identication of

risks of material misstatement• A list of information which is often obtained to support

our substantive audit of the estimate, along with a

listing of substantive procedures which will often be

appropriate in the context of the estimate and the

information described

• A list of common pitfalls that often arise in the audit of

the estimate

In the Staff Practitioner’s Examples section you will find:

• A description of factual situations where the estimate is

being considered

• A list of the audit procedures which the hypothetical

engagement team has already performed in testingmanagement’s process for establishing the estimate

• Descriptions of the most signicant deciencies in the

audit procedures

• Examples of some possible additional audit procedures

which may be considered in the circumstances

A meaningful way of using this material is in the planning

of your activities and as a support to the work you perform

or supervise. For example, an engagement partner may

find the Reviewer Considerations section of this estimate

helpful in planning the audit work, and in reviewing the

underlying working papers. Further, the staff auditor in this

situation may find the Staff Practitioner’s Examples section

to be helpful in executing his or her role in supervising or

performing the audit procedures.

Additional examples of estimates which illustrate new

principles and concepts will be added to the Practice Aid

when appropriate. If you believe there are such estimates,

contact the Audit Group in Wilton.

5

Preface

mailto:[email protected]




6 Environmental Liabilities

Environmental Liabilities

Introduction

The purpose of this section is to provide users with considerations relevant to assessing the

adequacy of procedures for auditing environmental liabilities. Environmental liabilities generally

represent estimated future obligations for clean-up costs or damages and may be recognized

in connection with environmental loss contingencies, environmental remediation liabilities,

environmental guarantees, and asset retirement obligations (ARO) (see discussion in ASC 410,

Asset Retirement and Environmental Obligations; the requirements for ARO estimates in ASC

410-20 are unique and not included in this section). Guarantees are discussed in ASC 460.

Environmental estimates and liabilities are frequently performance-based whereby certain

activities will be performed to achieve a desired objective or result (e.g., the remediation of

contaminated groundwater or soil).

Establishing these estimates requires the identification of a particular driver such as a

consent order issued by regulator, lawsuit, or asserted or unasserted claim to indicate a

liability has been incurred plus the activities or scope of work necessary and the supporting

details to measure the liability. The existence of a liability for environmental remediation

costs becomes determinable and the amount of the liability becomes estimable over

a continuum of events and activities that help to frame, define, and verify the liability.

In the early stages of the process, cost estimates can be difficult to derive because of

uncertainties about a variety of factors. Consequently, a multidisciplinary approach is

typically used to identify, understand, and measure these liabilities, and may includetechnical or engineering resources, legal, regulatory, and accounting competencies.

Environmental exposures frequently represent an understatement risk whereby (1)

management may not be aware of new or potential environmental exposures or incidents

or (2) management is aware of the environmental obligation and may assert that the

criteria for recognition has not been met (i.e., probable that the entity has incurred a

liability, however the loss is not reasonably estimable). The future cash outows related to

environmental matters may be deemed inestimable based on various factors (e.g., limited

information regarding volume and nature of contamination or what will ultimately be

required by the regulatory agency). While it may not always be possible to estimate the

entire liability, a portion of the liability can frequently be measured. In these cases a liability

should be recognized for that portion which can be estimated.

Whether notification by regulatory authorities in relation to particular environmental laws

and regulations constitutes the assertion of a claim is a matter of legal determination. If an

entity concludes that it has no current legal obligation to remediate a situation of probable

or possible environmental impact, then in accordance with paragraph 450-20-50-6 no

disclosure is required. However, if an entity is required by existing laws and regulations to

report the release of hazardous substances and to begin a remediation study or if assertion

of a claim is deemed probable, the matter would represent a loss contingency subject to

the disclosure provisions of paragraphs 450-20-50-3 through 50-4, regardless of a lack

of involvement by a regulatory agency. The d isclosure requirements of ASC 275-10 also

apply to environmental remediation liabilities. Other d isclosures related to environmental

liabilities may be appropriate (see ASC 410-30-50).

NOTE

These considerations provide example

procedures that an engagement team may

consider to enhance the effectiveness of their

audit. These consideration points are not

all-inclusive and are not intended to replace the

need for professional judgment. There may be

other acceptable ways to accomplish the auditobjectives for this management estimate that

are not specifically addressed herein. The nature,

timing, and extent of testing and audit evidence

that is appropriate will depend on the entity

specific facts and circumstances as well as our

approach to testing internal controls.

Reviewer Considerations

When identifying material classes of transactions,accounts, balances, and disclosures, we consider both

qualitative and quantitative factors. As we obtain an

understanding of the relevant industry, regulatory,

and other external factors, we may consider the

following qualitative factors related to contingent

environmental liabilities:

• The relevant legislation and regulations

• Environmental requirements affecting the industry

and the entity’s business

• The experience of the entity’s sector and

competitors

These factors may indicate an inherent risk and

susceptibility to misstatement that is not reected inthe account balance or the entity’s recent experience

related to the environmental exposures.



Reviewer Considerations (cont.)


Common Significant Assumptions (NOT ALL-INCLUSIVE)

• Technical assumptions regarding the expected scope of work to be required at a site:

– Interpretation of the scope of work expected as a result of the provisions of a consent decree, unilateral order, otherdirective issued by a regulator, claim or potential claim, or lawsuit

– Regulator approval of remedy and work plan

– Establishment (submission and confirmation) of site clean-up standards (e.g., residential standards or industrial use

standards)

– The range of activities expected to be required

– Duration of activities during remediation and operations, maintenance, and monitoring periods

– Activities and cost components considered to be “typical” of the industry

– The timing of future expenditures and the impact on the classification of the liability in the balance sheet

• Judgments about:

– The probability and estimability of a loss related to an exposure

– The allocation percentages assigned to parties identified as potentially responsible parties (PRPs) and subject to joint

and several liability or other cost sharing mechanisms

– The credit worthiness of the other PRPs and the likelihood they will pay their share of the allocated costs

– The cost build-up, including volumes and unit costs (internal and external cost)

– The application of accounting conventions (e.g., future cash ows are inestimable beyond 10 years)

• Consideration of facts and circumstances when an exposure is determined to not be estimable

• Classication of the liabilities based on the driver of environmental exposure (a remediation liability from an unexpected

incident versus contamination from normal operation of an asset accounted for as an ARO, both may be present at a site)

• Differentiating between required environmental remediation and voluntary activities or pollution control activities

Factors That Could Lead to Risks of Material Misstatement (NOT ALL-INCLUSIVE)

• Existing or new exposures associated with environmental contamination are not identied and assessed in a timely manner

• Relying on contractor estimates which were not developed for purposes of nancial reporting

• Management relies on an external specialist to understand and apply the applicable accounting standards (e.g., U.S.

GAAP, IFRS) and the external specialist does not have an adequate understanding of the accounting standards

• Management’s internal or external specialist does not have the relevant experience or does not have the competency to

be able to provide advice or a particular liability estimate

• Judgments and estimates are not subject to sufcient review by management

• Decisions whether to modify the reserve are not subject to the appropriate level of review by management

• Management does not incorporate new data into the assessment of the liability

• All cost elements may not be included in the measurement of the environmental liability or may not be priced appropriately

• The costs included in the estimate may be several years old or based on old assumptions

• The entity’s policies state that liabilities are recorded when notice of a claim is received versus when it is probable that a

claim will be asserted that will result in an unfavorable outcome

• Management’s policy is interpreted as requiring the reserve be recorded at the low end of the range rather than the

best estimate

• Liabilities viewed by the entity as probable but not reasonably estimable can be estimated within a reasonable range

based on available information• The entity has a recovery mechanism (e.g., insurance or indemnity) and the receivable has been improperly netted

against the liability

• Management bias inuences the assumption used and judgments made

• Financial assurance costs (e.g., performance guarantee mechanisms such as bonds, letters of credit) are included in the

estimate versus treated as a period cost

• The cost estimate has been based on a scope of work that is not responsive to regulatory requirements or consistent

with ASC 410-30

• The entity discounts contingent liabilities that do not qualify for discounting as the timing and amount of the future

cash ows are not xed or reasonably determinable or the discount rate is not consistent with the rate used in other

internal analyses (note: if the low end of a range of possible losses were accrued, SEC staff comments have indicated that

discounting would not be appropriate because the aggregate obligation is not fixed and reliably determinable)

Superfund is the

name given to theenvironmental program

established to address

abandoned hazardous

waste sites. It is also

the name of the

fund established by

the Comprehensive

Environmental Response,

Compensation and

Liability Act of 1980, as

amended. It allows the

Environmental Protection

Agency (EPA) to cleanup such sites and to

compel responsible

parties to perform

clean ups or reimburse

the government for

EPA-led clean ups. The

Superfund clean-up

process is complex. It

involves the steps taken

to assess sites, place

them on the National

Priorities List, and

establish and implement

appropriate clean-up

plans.

Similarly, under the

corrective action

requirements of the

Resource Conservation

and Recovery Act of

1976 (RCRA), the EPA

may order facilities that

treat, store, or dispose

of hazardous waste

to clean up releasesof hazardous waste

constituents associated

with past or ongoing

practices. In addition

to these programs,

there are numerous

federal and state

environmental laws that

may impact an entity’s

business and result in an

environmental exposure.





• The costs to treat environmental contamination are capitalized rather than charged to expense

• The entity does not track aggregate possible losses to determine if possible losses in excess of the reserves recorded are

significant and should be disclosed• The entity does not disclose that environmental liabilities are discounted and the amount of the d iscount

• The reserves are overstated to preserve remediation budgets or to serve as “cookie jar” reserves

• The entity does not make all of the required disclosures




In the context of environmental remediation liabilities, the probability criterion in ASC 450-20-25-2 consists of two elements.

The criterion is met if both of the following elements are met on or before the date the financial statements are issued:

• Litigation has commenced or a claim or an assessment has been asserted, or, based on available information, commencement

of litigation or assertion of a claim or an assessment is probable. In other words, it has been asserted (or it is probable that it

will be asserted) that the entity is responsible for participating in a remediation process because of a past event.

• Based on available information, it is probable that the outcome of such litigation, claim, or assessment will be unfavorable.

What constitutes commencement or probable commencement of litigation or assertion or probable assertion of a claim or

an assessment in relation to particular environmental laws and regulations may require legal determination.

Certain stages of a remediation effort or process and PRP involvement provide benchmarks that may be considered whenevaluating the probability that a loss has been incurred and the extent to which any loss is reasonably estimable. The

following are recognition benchmarks for a Superfund remediation liability. Analogous stages of the RCRA corrective-

action are also listed in ASC 410-30-25-15.

Identification as a PRP: If an entity

receives notification or otherwise

becomes aware that it may be a

responsible party, it should examine

its records to determine if it has

been associated with the site. If the

entity determines that it is

associated with the site, it is

probable that a liability has been

incurred. If all or a portion of the

liability is reasonably estimable, the

liability should be recognized.

Receipt of unilateral

administrative order: If an entity

receives an order to take action or

risk penalties, management should

accrue a liability for the requisite

work. The cost of performing the

requisite work generally is

estimable within a range and

recognition of a liability for costs of

the study and any other short-term

actions generally should not be

delayed beyond this point.

Participation in a remedial

investigation-feasibility study: If

an entity agrees to pay the cost of

a study, it should accrue a liability

for its share of the cost of the study

and any other costs that can be

reasonably estimated. As the study

proceeds, the entity’s estimate of

its share of the total cost of the

study can be refined.

Completed feasibility study:

At substantial completion of the

feasibility study, a minimum liability

generally will be reasonably

estimable. If management had not

previously concluded that it could

reasonably estimate the liability,

recognition should not be delayed

beyond this point.

Issued record of decision: The EPA

specifies a preferred remedy, which

further refines the amount of the

potential liability. Management’s

estimate normally can be refined

based on the specified preferred

remedy and a preliminary allocation

of the total remediation costs,

which will likely result in an

adjustment to the liability.

Remedial design through

operation and maintenance:

This phase includes actual site

remediation and involves the most

precise cost estimates, which

management uses to continue to

refine its liability adjustments. This

phase continues through

post-remediation monitoring.

1 2 3

4 5 6

An entity should determine its allocable share of liability for a site based on its estimate of the allocation methods and

percentage that will ultimately be used for the entire remediation effort. The primary source for this estimate should be

the allocation method and percentages that (1) parties have agreed to, (2) have been assigned by a consultant, or (3) have

been determined by a regulator. If the entity’s assessment of the ultimate allocation method and percentage differs from

these primary sources, the entity’s estimate should be based on objective, verifiable information including data about

the kinds and quantities of waste at the site, experience with allocation approaches in comparable situations, reports of

specialists, or other data refuting contributions to the site.


CAUTION

The following provides useful information about U.S. GAAP and the Financial Accounting Standards Board’s Accounting Standards Codication (the

“Codification”) that may be considered when auditing environmental liabilities. It may be helpful to provide context to the audit procedures and considerations

that are outlined in this Section. The information was extracted from ASC 410-30 and it not intended as a substitute for the understanding of U.S. GAAP andthe Codification and the exercise of judgment. Engagement teams should have a thorough understanding of the Codification and should refer to the text of the

Codification, as necessary, in considering particular items presented below.



1 The examples provide illustrative procedures that may assist in evaluating whether sufficient appropriate evidential matter has been obtained in connection with our audit of

management’s estimates. The example procedures indicated as “Procedures typically performed that may be incomplete” often are not sufficient and appropriate for management

estimates when performed alone. Limiting the nature, timing, and extent of procedures to these items, and not combining these procedures with other testing procedures, might

result in inadequate audit procedures as identified in internal and external inspection findings. The examples indicated as “Additional procedures we might perform” present

additional audit procedures that, individually or in some combination, may improve audit performance.

Consider the significance, complexity, and estimation uncertainty of the management estimate being tested to determine the additional aud it procedures, if any, that might be

relevant in the circumstances.

10

EVALUATE DEGREES OF EVIDENCE

The determination of the nature, timing, and extent of procedures, and also the degree of documented evidence needed to support those

procedures, is a professional judgment dependent upon specific facts and circumstances.

Whatever the facts and circumstances, the documentation of the procedures performed would demonstrate the sufficient appropriate

evidence obtained, the conclusions we reached, and the basis for our conclusions regarding the reasonableness of the estimate.

100˚

90˚

80˚

70˚

60˚

50˚

40˚

30˚

20˚

10˚

0˚

C nt r t rEv n

t vEv n

B l n

In t lEv n



Information we typically

receive

Audit procedures

internal process flow

narratives and internal

control matrices

Procedures typically performed that may be incomplete1

• Conduct and document high-level discussions with management to update the prior-

year understanding

• Identify controls (e.g., review and approval of journal entries, reviews by senior

management of environmental specialist’s reports) that may not consider all thesignificant aspects of developing the estimate, may not be sufficiently precise to meet

the relevant assertions, or address the risks of material misstatements associated with

the relevant financial statement assertions

• Assess the design of controls by considering some of the important attributes of the

control

• Tests of operating effectiveness for a portion of the important attributes of the control

(e.g., only inspecting the documentation evidence of the reviewer’s sign-off)

• Determine how the responsibility for monitoring environmental liabilities is shared

between Environmental, Health, and Safety (EH&S) and the legal department

Additional procedures we might perform1

• Obtain management’s current-year process ow descriptions and control matrices

and compare them with the prior year to identify whether any changes in the process

or controls occurred• Enhance our understanding of the likely sources of misstatements by updating and

supplementing the prior-year understanding, including asking probing questions and

obtaining corroborative evidence related to the following:

– New or potential environmental exposures

• Who reviews the list for completeness

CAUTIONCommon pitfalls

• Failure to identify relevant controls that are designed to specically address the identied risks of material misstatement and operate at a sufcient level of precision

• Failure to assess important attributes of the design of controls identied

• Failure to appropriately challenge the sufciency of management’s process• Failure to perform substantive tests of the underlying data used to develop the estimate

• Failure to challenge whether no change in the recorded balance year over year is appropriate

• Failure to adequately understand the external specialist’s methodology and/or assumptions

• Failure to reconcile or understand differences between the external specialist’s calculation and the amount recorded by management

• Failure to adequately address and document matters raised by the Environmental Specialist

• Failure to challenge if an exposure is truly not probable or estimable• Failure to document all of the considerations made by the Environmental Specialist in nding that the management’s estimates were reasonable (i.e., the basis for the

Environmental Specialist’s conclusions)

• Failure to corroborate comments made by management or the external specialist engaged by management• Failure to retrospectively review actual costs compared to estimated costs, where appropriate, for management bias and to assess if management has demonstrated

proficiency in determining the estimate

• Failure to properly determine whether costs to treat environmental contamination should be capitalized or charged to expense

• Failure to apply the appropriate accounting treatment or classication which may result in recognition or measurement differences• Failure to include the appropriate disclosures (e.g., lack of appropriate disclosure of sites where the amount is not estimable)

• Failure to document sufcient information regarding the procedures performed and professional judgments made to enable an experienced auditor, having no previous

experience with the engagement, to understand the nature, timing, and extent of the procedures performed, the evidence obtained, and the conclusions reached

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receive

Audit procedures


narratives and internalcontrol matrices (cont.)

Additional procedures we might perform1 (cont.)

• What activities are designed to identify, monitor, and measure incidents orexposures and the impact on the related disclosures

• What controls exist to ensure consistency in evaluation of probabilities

– Relevant controls to review the key assumptions and cost build-up used to estimate

the reserve and related documentation

– Relevant controls to review whether a reserve adjustment should be recorded

– Appropriate participation of resources with technical and engineering, legal,

regulatory, and accounting competencies in the preparation and review of the

remediation cost estimates and the reserves

– The appropriateness of the entity’s accounting policies related to remediation liabilities

– The process by which data that could affect disclosures is tracked, aggregated,

communicated, and reviewed

– How any overlap between environmental remediation liabilities, AROs, and voluntary

and/or future expenditures required for pollution control are reviewed and addressed– Frequency and adequacy of the entity’s review processes to update remediation

reserve estimates

• Identify controls that mitigate the risks of material misstatement of environmental

liabilities and evaluate the adequacy of the level of precision at which the control

operates, which may include:

– Purpose of the control. A procedure that functions to prevent or detect

misstatements generally is more precise than a procedure that merely identifies and

explains differences (e.g., a detailed review of the calculation of the environmental

liability reserve including the supporting regulatory or legal orders and assumptions

by someone knowledgeable of ASC 410-30 is generally more precise than a

procedure that identifies and explains differences between the recorded reserve and

the report prepared by the specialist engaged by management)

– Level of aggregation. A control that is performed at a more granular level

generally is more precise than one performed at a higher level (e.g., an analysis of

environmental liabilities by site normally is more precise than an analysis of total

environmental liabilities)

– Consistency of performance. A control that is performed routinely and consistently

generally is more precise than one performed sporadically

– Correlation to relevant assertions. A control that is indirectly related to an assertion

normally is less likely to prevent or detect misstatements in the assertion than

a control that is directly related to an assertion [e.g., a detailed review of the

calculation of the environmental liability reserve including the supporting regulatory

or legal orders and assumptions by someone knowledgeable of ASC 410-30 would

not likely address the completeness assertion (i.e., there are no material omissions

from the reserve)]

– Criteria for investigation. For detective controls, the threshold for investigating

deviations or differences from expectations relative to materiality is an indicationof a control’s precision (e.g., a control that investigates items that are near the

threshold for financial statement materiality has less precision and a greater risk

of failing to prevent or detect misstatements that could be material than a control

with a lower threshold for investigation)

Assess whether other audit

evidence obtained elsewhere

in the audit contradicts or

is inconsistent with any

assumptions used in developing

the estimate.













receive

Audit procedures


narratives and internalcontrol matrices (cont.)

– Predictability of expectations. Some entity-level controls are designed to detect

misstatements by using key performance indicators or other information to developexpectations about reported amounts. The precision of those controls depends

on the ability to develop sufficiently precise expectations to highlight potentially

material misstatements [e.g., the EH&S Director’s review of a summary of the

three-year trend line of total expenditures would not likely detecting material

misstatements because the EH&S Director is merely reviewing the trend reports

for indications that the balance may be wrong (i.e., nothing came to his or her

attention that would indicate the balance is materially misstated)]

– The completeness and accuracy of any reports or information that the control is

dependent upon

• Perform tests of the relevant controls, including evidence to verify each of the

important attributes of the design of the control (e.g., observation of meetings in

which the control is performed, and reperformance of the review)

• Specically indicate the degree of Estimation Uncertainty associated with each

aspect of the process and tailor the substantive procedures accordingly

• When assessing the qualications and objectivity of environmental specialists engaged

by the entity, specifically assess and document the professional qualifications and the

nature of any relationship with the entity that may impair or appear to impair the

objectivity of the work

Rollforward of

environmental exposures

and claims including

any new environmental

incidents, fines, and

violations which may be

indicative of exposuresand claims


• Agree the beginning balance to prior year working papers and agree ending balance

to the general ledger

• Hold discussions with management regarding the status of each site

• Read any new relevant information related to existing environmental exposures/

incidents, fines and violations, and claims

• Read relevant information related to new environmental exposures/incidents, nesand violations, and claims

• Test the rollforward for completeness

– Consider the following sources of information to identify missing environmental

exposures or incidents, fines and violations, and claims:

• The entity’s incident reporting system

• Internal audit reports and ndings

• EH&S compliance audit reports and ndings, which are frequently managed at

the facility or business unit level

• Legal letters from in-house and external legal counsel

• Disbursement testing and other audit procedures performed

– Make inquiries of management, in-house legal counsel, business unit leadership,

EH&S leadership, and facility personnel

– Perform a public domain search using Google and Factiva to identify any events,issues, or claims reported in the media

• Review changes to the reserve balances for any unusual variances that are

inconsistent with our understanding


Because of the

complexity and highly

specialized knowledge

and experience in

identifying, assessing,

and measuring financial

information, multiple

competencies may

need to collaborate to

determine if and how

to report a contingent

environmental liability:

• Legal counsel

must determine

the likelihood that

an asserted claim

will result in an

unsuccessful outcome

• Environmental

scientists, engineers,

and financial experts

work with legal

counsel to estimate

the amount of

probable loss

• Accountants

determine whether

the amount of theloss, individually or in

the aggregate with

other environmental

liabilities, are material

Consider if tests of

IPE that support

the control activities that

management undertakesneed to be performed

on the reports we use in

our substantive testing,

and/or that are used to

support management’s

control activities where

we test those control

activities.

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Retrospective reviews can be an

effective technique to assess if

management has demonstrated

proficiency in determining the

estimate and to understand

whether management has a

tendency to skew estimates

with bias.










receive

Audit procedures

Rollforward of

environmental exposures

and claims including

any new environmental

incidents, fines, and

violations which may be

indicative of exposures

and claims (cont.)

Procedures typically performed that may be incomplete1 (cont.)

• Make a selection of exposures and claims for further testing

• Evaluate the current versus the noncurrent classication of environmental liabilities

• Evaluate the discount rate and whether the costs that were discounted met the

criteria of ASC 410-30-35-12 (i.e., timing of cash payments is fixed or reliably

determinable)


• Consider the circumstances and factors in U.S. AAM G018.03–.04 to determine the

nature and involvement of an Environmental Specialist

• In order to establish an understanding with the Environmental Specialist regarding the

nature of his or her assistance to the audit team, perform the following:

– Conduct a planning meeting

– Consider including the Environmental Specialist in the walkthrough– Complete a detailed scoping memo that summarizes the allocation of the

procedures between the Environmental Specialist and the audit team. Agree that

the Environmental Specialist will provide a memo and supporting working papers

that document the procedures performed and the conclusions reached

– Prior to the Environmental Specialist completing his or her planning memo, arrange

a planning call with the Environmental Specialist, the EH&S Director, the Controller,

and specialists engaged or employed by the entity in order to understand the

scope of the work performed by management’s specialist, the methodology used

in estimating the reserves, sources of information, key assumptions, and important

administrative matters to facilitate the engagement team’s procedures

• Involve an Environmental Specialist to assist with testing the entity’s process for

understatement by performing the following:

– U.S.: Conduct a search of the regulatory, legal, and other databases in the public

domain to identify environmental events, lawsuits, news items, and violations

reported during a stated period. Such databases tend to be based on U.S. events or

exposures

– International: Conduct a search of Factiva and other international news services

and local jurisdiction regulatory databases, if available. Searches may be possible in

some countries but require coordination with other DTTL Member Firms and may

require submitting a request for information to a national or municipal government

office

– Compare results of the searches to (1) the incident reporting system and (2) the

litigation and claims listing to access completeness

• Involve an Environmental Specialist to assist in the identication of industry/sector or

peer group environmental exposures reported in the public domain

• Assess the process and documentation maintained if the entity has determined a

reserve adjustment is not required for a site or a period


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receive

Audit procedures

For those cost estimates

selected for further

testing, support for the

cost estimates used as

the basis for the reserve

(e.g., engineering reports,

management’s analysis

or estimates, regulatory

orders)


• Reconcile the cost estimate in the engineering report or other detailed estimate to the

general ledger

• Read the engineering report or cost estimate for consistency with the stated

requirements (e.g., general scope of effort) in the consent decree or other directive

• Compare recent expenditures to the amount for the same period/tasks from the

engineering report cost estimate or other detailed estimate and consider the impact

on projections

• Detail test the current year spending by obtaining the respective support (e.g., invoice

and canceled check) and determine:

– If the expenditure was appropriately applied against the respective reserve and task

– If the expenditure was recorded for the correct amount

– If the nature of the expense was appropriate (e.g., incremental costs directly relatedto the remediation or other d irect internal costs)

– The effect, if any, on estimated future expenditures, if the spending is related to an

overrun

• Read related regulatory correspondence or approvals for additional information and

new developments which have affected or should affect management’s estimates

• Read correspondence from the party(ies) managing the clean up at the site (e.g., PRP

Committee, site operator) for additional information and new developments which

have affected or should have affected management’s estimates

• Inquire of management regarding key assumptions used to develop the estimate

which may include the following:

– Assumptions regarding the allocation of responsibility (i.e., PRP allocation)

– The timeframe and scope associated with long-term remediation efforts and post-

remediation operations, maintenance, and monitoring– Recovery opportunities (e.g., insurance, indemnities, cost recovery)

– Basis for estimating the costs (e.g., internal rates, external market rates, inclusion of

other internal direct costs, legal costs, regulatory oversight costs)

– Utilization of a life cycle cost estimation approach (i.e., consideration of costs

expected to be incurred over the lifetime of the remediation as compared to only

the cost of the current activities)

• Assess whether the credit worthiness of other PRPs has been appropriately considered

in the entity’s assessment and measurement of its PRP allocation

• Assess the funding mechanism used to manage the site, if applicable and determine

whether the trust fund/account has been set up as a separate legal entity under a

trust agreement or represents a cooperative account controlled by the parties

• Obtain from the entity a list of financial assurances (i.e., performance guarantees)

provided to the government or regulatory agencies and confirm a similar liability is

recorded (e.g., contingent liability or ARO) [note: statutory measurement requirements

may vary from the applicable accounting standard (e.g., U.S. GAAP, IFRS)]







the estimate.



Retrospective reviews can be an

effective technique to assess if



estimate and to understandwhether management has a


with bias.










receive

Audit procedures









orders) (cont.)


• Read the engagement letters between the entity and its external environmental

specialist to assess the relevance of the specialist’s report and any potential for

bias or manipulation [e.g., the intended use or purpose of the external estimates is

inconsistent with the applicable accounting standard (e.g., U.S. GAAP, IFRS)]

• Determine the key regulatory requirements and drivers for the site

• Read the regulatory documents and identify what requirements and tasks are active

and/or open as some requirements from previous orders from the regulator may be

unresolved

• Reconcile the regulatory requirements stated in the consent decree, regulations, or

other directive to the scope of work included in the engineering cost estimate or

other detailed cost build-up by considering the following:

– Extent of investigation and study required– Alignment of the geographic coverage of the estimate with the requirements

– Process and status of report submissions and approvals [note: guidance related to

staging and milestones and the presumption that costs should be estimable are

included in ASC 410-30]

– Progress and success with remediation performed to date

– Identification of remediation that is likely to require an extended timeframe and the

timeframe is not specified by the regulator as it is objective based

– Expected post-remediation operations, maintenance, and monitoring scope and

time frame

• Identify gaps in the scope of work due to uncertainties resulting from open

investigations, indecisiveness or inaction by the regulator, or ongoing negotiations

with the regulator

• Assess the reasonableness of the engineering estimate or detailed cost build-upbased on available supporting information (e.g., contracts, bids, drawing, workplans),

industry practice, and cost benchmarks

• Assess the reasonableness of the estimate as “most probable.” If there is no more

probable estimate, assess the range of possible costs and the points within the range

used for the reserve balance and for disclosure purposes [note: ASC 410-30-25

provides for the low end of the range to be recorded if there is no more probable

amount within the range]

• Corroborate information provided by management regarding the status of the site,

the regulatory interest and requirements, and any offsite or related community

exposures to the information available in the public domain

• Perform a site visit to conrm the status of the site

• Challenge management’s assertion when no accrual has been recorded

• Assess the adequacy and completeness of the entity’s documentation regarding key

assumptions, impact of uncertainties and alternative scenarios. Such assumptions are

frequently embedded in the engineering estimate

• Assess the methodology utilized by the entity to estimate the liability (e.g.,

probabilistic modeling, actuarial approach, range of possible costs)


Consider using an

Environmental

Specialist (see

U.S. DPM 10610.127)

to perform some of the

procedures.

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receive

Audit procedures









orders) (cont.)

Additional procedures we might perform1 (cont.)

• Perform the following procedures to identify possible management bias in the entity’s

estimate:

– Perform a retrospective review by comparing current period payments to prior-year

estimates to evaluate the accuracy of the entity’s prior cost estimates

– Determine if overruns are consistently recorded or experienced

– Assess whether there are inconsistencies with observable marketplace assumptions

(e.g., impacts of new environmental regulation or technology, evolving standards of

what constitutes acceptable remediation)

– Evaluate whether the historical results of our retrospective review indicate a pattern

of excessive optimism or pessimism

– Evaluate whether the historical results of our retrospective review uctuate with the

overall financial performance of the entity (e.g., the reserves were increased whenthe entity’s financial performance exceeded analysts’ expectation but decreased

when analysts’ expectations were not met without any appropriate underlying

reason)

– Determine whether compensation is tied to remediation cost savings or other

aspects of environmental liabilities

• Evaluate any differences noted from management’s estimate, document the reason

for the variance, and perform additional procedures, if necessary, to adequately

resolve the difference

• If an insurance recovery is recorded, evaluate financial or other available information

regarding the insurer to support collectibility. If the insurer is experiencing solvency

issues, evaluate management’s analysis and rationale for amounts deemed collectible

• Evaluate the entity’s conclusion that the recovery of a receivable is probable,

overcoming the presumption that the insurance receivable is not realizable whennegotiations to reach agreement and resolve essential details (e.g., payment amounts,

the period of payment, and other provisions) are still ongoing

• Compare assumptions and judgments used with assumptions and judgments made in

other financial statement estimates (e.g., projections used by management for other

purposes such as the goodwill impairment analysis)

• Use the Professional Judgment Whitepaper to assist in applying judgment and

documenting consideration of the procedures performed and judgments made






CAUTION

The following examples focus on specific facts and circumstances used to illustrate and highlight certain procedures performed when auditing environmental

liabilities. Therefore this listing of procedures presented is not intended to be complete. When conducting an actual audit, additional procedures would be

necessary to obtain sufficient appropriate evidential matter in connection with our audit of environmental liabilities.


Staff Practitioner’s Examples

Example 1

Facts

• The Company is the sole responsible party for Site X for which remediation activities started in 20X5

• The reserve balance as of December 31, 20XX, represents the projected remediation costs for the next 10 years based

on the estimate prepared by the contractor engaged to assist in the remediation; the estimate was prepared to assist

the Company in understanding the lowest cost alternative

• Management asserts that costs cannot be estimated beyond 10 years, although information submitted to the regulatory

agency includes an estimate for the next 20 years

Note: For purposes of Example 1, assume that we performed the appropriate procedures to identify any

additional sites or projects that may require recognition or d isclosure under ASC 410-30 and did not

identify any other than Site X. The example is designed to focus attention on management’s assertion that costscould not be estimated beyond the 10-year period and that the control we identified over the estimation process lacked

sufficient precision to detect a material misstatement in the financial statements.

Audit procedures performed

• Conducted high-level d iscussions with the contractor and management to update the prior-year understanding of

management’s process

• Identied and tested one control — the CFO’s meeting with the contractor to review the contractor’s recommendations

and to approve the reserve balance on an annual basis

• Tested the control by reviewing the report and noting the CFO’s signature as evidence of the control operating effectively

• Detail tested current-year spending by obtaining the respective support (e.g., invoice and canceled check) and

determining whether the expenditure was appropriately applied against the reserve

• Reconciled the projected costs from the contractor’s report to the technical order and amounts recorded

• Compared the projected costs for the next 10 years to the current year spending and assessed the projected costs forreasonableness

Deficiencies in audit procedures

• We did not challenge whether the report prepared by the contractor was appropriate for audit purposes (i.e., whether

the report was prepared to assist the Company in estimating its environmental liability for financial reporting purposes

or to perform remediation tasks and establish a budget for spending through the next 10 years)

• We d id not evaluate the qualications and objectivity of the expert

• We did not understand management’s process sufciently, which resulted in a failure to identify all the risks and relevant

controls

• We d id not adequately evaluate the design of the control

• We d id not sufciently test the operating effectiveness of the control

• We d id not challenge whether there was a more probable amount in the range of outcomes other than the low end of

the range

• We d id not challenge whether the 10-year period for the remediation tasks was appropriate and whether costs may be

estimated beyond that period

• We d id not perform procedures to identify possible management bias

Potential additional audit procedures1

• To challenge whether the report prepared by the contractor was appropriate for audit purposes, we could have

performed the following procedures:

– Evaluated the qualifications and objectivity of the expert

– Obtained an understanding of the contractor’s work (e.g., reviewed the engagement letter to understand the terms

of the engagement)

Consider if tests of

IPE that support

the control activities that

management undertakes

need to be performed

on the reports we use in

our substantive testing,

and/or that are used to

support management’scontrol activities where

we test those control

activities.

1 The additional audit procedures that would apply and/or suffice are a matter of professional judgment based on specific facts and circumstances



Retrospective reviews can be aneffective technique to assess if



estimate and to understand

whether management has a


with bias.


– Understood the assumptions described in the contractor’s report, which may have indicated the nature of the

engagement or raised questions about the specialist’s understanding of U.S. GAAP or the specialist’s objective to

identify the lowest cost alternative– Evaluated the appropriateness of that contractor’s work as audit evidence for the relevant assertion

• To understand management’s process steps sufciently in order to identify additional relevant controls, we could have

performed the following procedures:

– Involved an Environmental Specialist to participate in our procedures to obtain our understanding to assist in

identifying the process steps, risks, and relevant controls including:

• Made inquiries of persons involved in the process

• Asked probing questions

• To evaluate the design of control, we could have considered the following factors to assist us in evaluating the design of

the control and enable us to better plan the tests of operating effectiveness of controls:

– Purpose of the control

– Level of aggregation

– Consistency of performance

– Correlation to relevant assertions

– Criteria for investigation

– Predictability of expectations

• To test the operating effectiveness of the control, we could have performed the following procedures:

– Attended the meeting between the CFO and the contractor to assess the extent and nature of the CFO’s interaction

and effectiveness of the review (observation)

– Examined the reports and any other supporting documents used in performing the control to understand the level of

detail available to the reviewer and tested the reports/documents for accuracy and completeness (inspection)

– Reviewed the report and data for anomalies and appropriate support for the assumptions and conclusions

(reperformance)

– Examined documentary evidence to validate the criteria for investigation used and follow up actions taken (inspection)

• To challenge whether there was a more probable amount in the range of outcomes other than the low end of the range

and the Company’s assertion regarding the 10-year period, we could have performed the following procedures:

– Involved an Environmental Specialist to assess:

• Whether the scope of the client estimate is responsive to the regulatory requirements and represents the most

probable amount

• The reasonableness of the 10-year period, considering the following:

Whether an indefinite remediation period is expected due to the nature of the contaminant

The regulatory order or the relevant regulations to determine if a time horizon is specified

The effectiveness of clean-up activities to date to assess the reasonableness of assumptions

The cost components and cost build-up of the reserve to determine consistency with U.S. GAAP

– Evaluated the reasonableness of recording the low cost alternative and the high end of the range of possible costs

which should be considered for disclosure. If there is no more probable estimate, assessed the range of possible

costs and the points within the range used for the reserve balance and for d isclosure purposes [note: ASC 410-30-25

provides for the low end of the range to be recorded if there is no more probable amount within the range]

• To identify possible management bias in the Company’s estimate, we could have performed the following procedures:

– Performed a retrospective review by comparing current-period payments to prior-year estimates to evaluate the

accuracy of the entity’s prior cost estimates

– Involved an Environmental Specialist to assess whether the key assumptions embedded within the estimate are:• Reasonable and appropriately identied in the documentation

• Consistent with observable marketplace assumptions (e.g., impacts of new environmental regulation or technology,

evolving standards of what constitutes acceptable remediation)

– Determined if overruns are consistently recorded or experienced

– Evaluated whether the historical results of our retrospective review indicate a pattern of excessive optimism or pessimism

– Evaluated whether the historical results of our retrospective review uctuate with the overall nancial performance

of the Company (e.g., the reserves were increased when the Company’s financial performance exceeded analysts’

expectation but decreased when analysts’ expectations were not met without any appropriate underlying reason)

– Determined whether compensation is tied to remediation cost savings or other aspects of environmental liabilities

Staff Practitioner’s Example (cont.)








the estimate.


Staff Practitioner’s Examples (cont.)

Example 2

Facts

• The Company has grown through acquisitions in the U.S. and continues to manage and track environmental exposuresat the business unit level

• Support for the reserve estimates and exposures are maintained at the business unit or facility level

• The EH&S Director reviews of a summary of the following environmental-related information, which includes a three-

year trend line of total expenditures, the total number of new issues identified during the period, the total number of

issues resolved, and the net change in the reserve on quarterly basis. The EH&S Director relies upon each business unit to

determine whether any exposure has met the criteria for recognition under ASC 410-30 (e.g., probable and estimable)

• The Company’s policy is to consider remediation obligations probable and reasonably estimable only when the

regulatory order has been agreed to

Audit procedures performed

• Obtained a list of environmental exposures or incidents, nes, violations, and claims

• Performed a public domain search using Factiva and Google to test the completion assertion

• Discussed signicant changes from the prior-year with the corporate-level management to update our prior-year understanding

• Evaluated design of the control, determined whether it was implemented, and tested the operating effectiveness

• Veried that the Company’s policy was consistently followed

Deficiencies in audit procedures

• We d id not adequately assess whether the list of environmental exposures or incidents, nes, violations, and claims was

complete

• We d id not challenge whether the control is effective at detecting material misstatements — either overstatements or

understatements in the estimates — because the EH&S Director is merely reviewing the trend reports for ind ications that

the balance may be wrong (i.e., nothing came to their attention that would indicate the balance is materially misstated).

The EH&S Director would not be able to determine that:

– There are no material omissions from the reserve

– One or more of the key assumptions were appropriate

– There are no material errors in the underlying calculations

– The Company is measuring its exposures on a consistent basis (e.g., each business unit may have different criteria for

reporting environmental exposures or incidents, fines, violations, and claims)

– Management at the business unit has the appropriate knowledge and competence of U.S. GAAP

• We did not challenge whether the Company’s policy (i.e., consider remediation obligations probable and reasonably

estimable only when the regulatory order has been agreed to) is in accordance with U.S. GAAP








the estimate.


Staff Practitioner’s Examples (cont.)

Potential additional audit procedures1

• To challenge whether the list of environmental exposures or incidents, nes, violations, and claims was complete, we

could have performed the following procedures:– Considered the following sources of information to identify missing items:

• Incident reporting

• Internal audit reports and ndings

• EH&S compliance audit reports and ndings

• Legal letters from in-house and external counsel

• Disbursement testing and other audit procedures performed

– Corroborated inquiries of management, internal legal counsel, business unit leadership, EH&S leadership, and facility

personnel

– Involved an Environmental Specialist to assist to conduct a search of the regulatory, legal, and other databases in the

public domain to identify environmental events or releases, cases, news items, violations reported during a stated period

• To challenge whether the control is effective at detecting material misstatements, we could have performed the

following procedures:

– Understood the process and identified controls for recording a liability at the business-unit level in addition to our

understanding at the corporate-level

– Corroborated our understanding obtained from discussions with corporate-level management with management at

the business unit level

– Assessed whether the business unit management has the appropriate knowledge and competence to determine when

a liability should be recorded (i.e., does business unit management understand the objectives of the reserve process)

– Included an Environmental Specialist in updating our understanding that includes questioning business unit personnel

about their understanding of what is required by the Company’s prescribed procedures and controls at the points at

which important processing procedures occur

• To challenge whether management’s policy to consider remediation obligations probable and reasonably estimable only

when the regulatory order has been agreed to is consistent with ASC 410-30, we could have performed the following

procedures by teaming with an Environmental Specialist:

– Performed a site by site analysis to consider the specific requirements and circumstances for each site

– Considered whether a portion of the remediation costs may be estimated [note: at the early stages of the remediation

process, particular components of the overall liability may not be reasonably estimable. This fact should not preclude

the recognition of a liability. Rather, the components of the liability that can be reasonably estimated should be

viewed as a surrogate for the minimum in the range of the overall liability]

– Assessed whether the site situation is common or similar to situations at other sites with which the Company has

been associated (e.g., the remediation involves only the removal and disposal of contaminated soil and on-going

groundwater monitoring, similar to other company sites) and therefore the liability can be reasonably estimated

1 The additional audit procedures that would apply and/or suffice are a matter of professional judgment based on specific facts and circumstances



Contacts

For more information please contact:

Mark Loizeaux

Partner

Audit Group

Wilton

+1 203 761 3081

[email protected]

Shelby Murphy

Audit Senior Manager

Audit Group

Wilton

+1 203 761 3160

[email protected]

Questions concerning the Practice Aid can also be d irected to National Office (Audit Consultation)

or +1 866 547 1725.

About Deloitte

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms,

each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal st ructure of

Deloitte Touche Tohmatsu Limited and its member firms. Please see www.deloitte.com/us/about for a detailed description of the legal structure of

Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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Documents

Exploring Leading Practices for Environmental Liabilities