Accounting Guidelines for Environmental Issues
Dr. L. Murphy Smith
Website Article © 2003


Regarding auditing, once environmental risks have been identified, the auditor must check for compliance with accounting standards. Several rules governing environmental disclosures have been developed in recent years. At the highest level of generally accepted accounting principles (GAAP) are the Statements of Financial Accounting Standards (SFAS) which are issued by the Financial Accounting Standards Board (FASB). The FASB Emerging Issues Task Force (EITF) was formed in July 1984 to assist the FASB identify emerging issues affecting financial reporting and resolve problems in implementing authoritative pronouncements. A consensus position reached by the EITF is GAAP that must be followed unless it conflicts with a FASB Statement, Interpretation or Technical Bulletin, APB Opinion, Accounting Research Bulletin, SOP, or AICPA Industry Audit and Accounting Guide. EITF consensus positions generally are effective upon issuance. Statements of Position (SOP) are issued by the Accounting Standards Executive Committee of the American Institute of CPAs (AICPA). Some of the key accounting pronouncements that regard environmental reporting are the following:

(1) SFAS No. 5 states under "Accounting for Contingencies" that a liability should be recognized in the financial statements if a loss is probable and the amount is estimable. If the loss amount is not estimable which is often the case, the contingency must be described in the footnotes to the financial statements.
(2) ETIF Issue No. 90-8 required that all environmental contamination costs be expensed as incurred unless costs extend the life or increase capacity of the property, costs mitigate or prevent future environmental contamination (that would otherwise occur), or costs are incurred to prepare a property for sale.
(3) ETIF Issue No. 93-5 concluded that an environmental liability must be evaluated independently from any potential claim for recovery. This recovery claim can reduce the liability only if it is probable. Securities Exchange Commission (SEC) standards state that it is appropriate to net the asset and liability if the asset’s recovery is recognized as probable. The asset and liability should be disclosed in the notes to the financial statements. The SEC approves discounting of liabilities to their present value. The Management Discussion and Analysis section of the annual report requires "forward looking" disclosures. The SEC in Interpretation No.14 states that registrants must take reasonable steps to identify the minimum end of the loss range with a higher priority on studying sites where a known problem exists. Registrants should assess the probability of an environmental obligation and any insurance recovery independently. Post-remediation monitoring approaches have been developed.
(4) AICPA Statement of Position (SOP) 96-1, “Environmental Remediation Liabilities,” covers auditing and accounting topics dealing with environmental issues. It details the responsibilities of corporations involved in environmental cleanup, and responsibilities of corporations to avoid environmental destruction. SOP 96-1 is a comprehensive environmental issues guide.

Thousands of sites in the U.S. have been contaminated and directed to be cleaned up by the Environmental Protection Agency. Laws now require responsible parties to pay to clean up their past contamination, which is often expensive. In response to consumer interests and regulatory enforcement, some corporations have had to change their way of doing things. Some firms have had to learn to recycle, limit waste output (air pollution, water pollution, soil pollution), and most importantly, follow their hazardous products from creation to final disposal. Consequently, for many organizations, significant risks surround environmental issues. As penalties have increased for poor environmental choices, many companies are paying closer attention to regulations, often going beyond what is required.



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