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Significance and Use
Uses—This guide is intended for use on a voluntary basis by a reporting entity that provides disclosure in their financial statements regarding environmental liabilities. The degree and type of disclosure depends on the scope and objective of the financial statements. Note the user should be aware that there may be contractual obligations, court decisions, or regulatory directives that may affect the flexibility in use of this guide.
The following principles are an integral part of this guide and are intended to be referred to in resolving any ambiguity or dispute regarding the interpretation of disclosures regarding environmental liabilities.
Uncertainty Not Eliminated—Although a reporting entity, as of the time when its financial statements are prepared, may hold a certain position with regard to the existence and extent of its environmental liabilities, there remains uncertainty with regard to the final resolution of factual, technological, regulatory, legislative, and judicial matters, which could affect its environmental liabilities.
Disclosure Dependent on Circumstances—Not every environmental liability warrants the same level of detail in its disclosure. Disclosure will be guided by the scope and objective of the financial statement, and accordingly, by the materiality of the environmental liability and the level of information available.
Comparison with Subsequent Disclosures—Subsequent disclosures that convey different information regarding the extent or magnitude of the reporting entity's exposures should not be construed as indicating the initial disclosures were inappropriate. Disclosures shall be evaluated on the reasonableness of judgments and inquiries made at the time and under the circumstances in which they were made. Subsequent disclosures should not be considered valid standards to judge the appropriateness of any prior disclosure based on hindsight, new information, use of developing analytical techniques, or other factors. However, information on trends may be of value to a user of financial statements.
Not Exhaustive—Appropriate disclosure does not necessarily mean an exhaustive disclosure of the reporting entity's environmental liabilities. There is a point at which the cost of obtaining information or the time required to gather it outweighs the usefulness of the information and, in fact, may be a material detriment to the orderly preparation of financial statements and the ability of readers to understand the information contained therein. However, all relevant and reasonably ascertainable information should be used to determine the content of appropriate disclosure for environmental liabilities.
Assessment of Risk—As the reporting entity becomes aware of an environmental liability or an environmental compliance issue, the condition or issue should be evaluated to assess the actual or potential risk to human health and environment. This process may be dependent on the regulatory environment, an understanding of the specifics of the condition or issue, potential future uses, and asset retirement obligations. For example, guidance on petroleum release sites is provided in Guide E1739 and additional guidance is provided in EPA OSWER Directive 9610.17. The degree of risk suggests the appropriate response actions and should be a factor in the level of effort devoted to developing the cost and liability estimates associated with the environmental condition or the compliance issue.
1.1 Purpose—The purpose of this guide is to provide a series of options or instructions consistent with good commercial and customary practice in the United States for environmental liability disclosures accompanying audited and unaudited financial statements. This guide is consistent with Generally Accepted Accounting Principles (GAAP).
1.2 Objectives—The objectives of this guide are to determine the conditions warranting disclosure and the content of appropriate disclosure.
2. Referenced Documents (purchase separately) The documents listed below are referenced within the subject standard but are not provided as part of the standard.
EPA DirectivesUnitedStatesEnvironm Use of Risk-Based Decision-Making in UST Corrective Action Programs
D5746 Classification of Environmental Condition of Property Area Types for Defense Base Closure and Realignment Facilities
E1527 Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process
E1739 Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites
E2137 Guide for Estimating Monetary Costs and Liabilities for Environmental Matters
ICS Number Code 13.020.10 (Environmental management)