外文出处Business & Economic Review,2006(4):21-27外文作者布莱恩.斯坦科,艾琳.布罗根,艾琳,亚历山大,约瑟芬.蔡.梅齐原文:Environmental AccountingHere's why projected cleanup costs from hazardous waste sites will be findingtheir way onto the balance sheets of Corporate America.Monitoring the production and disposal of hazardous waste has been a top priority of the United States government and the Environmental Protection Agency (EPA) since the mid-1970s, largely as a result of the Love Canal environmental disaster. Unfortunately, the remediation of hazardous waste sites is not finished, and cleanup cost estimates range anywhere between $500 billion and $1 trillion. American corporations will ultimately be held accountable for these costs. What remains to be seen, however, is exactly who, when, and how much.In terms of corporate responsibilities, this article discusses requirements regarding the financial reporting of environmental liabilities and current initiativesthat should improve the measurement and disclosure of these liabilities. Investors and business professionals alike must understand the significance of these obligations asthey relate to current and future corporate financial statements.Financial ReportingFinancial reporting requirements have evolved over time under several governing bodies. The Securities Act of 1934 created the Securities and Exchange Commission (SEC) and gave it the authority to administer federal securities laws and prescribe accounting principles and reporting practices. Companies that are considered under the jurisdiction of the SEC include any company whose stock is publicly traded. As a result, these companies are required to follow SEC disclosure requirements in their filings.The Financial Accounting Standards Board (FASB) is responsible for establishing the current standards of financial accounting and reporting. The standardsor pronouncements that the FASB issues, "Statements of Financial Accounting Standards" (SFASs), are officially recognized as authoritative by the Securities and Exchange Commission and the American Institute of Certified Public Accountants (AICPA), the national professional organization of CPAs.Until recently, the AICPA played a prominent role in the accounting and reporting environment. But as a result of the Sarbanes-Oxley Act of 2002, the AlCPA's Auditing Standards Board (ASB) was limited in its role of establishing Generally Accepted Auditing Standards. Auditing and related professional practice standards as they pertain to public companies are now established by the Public Company Accounting Oversight Board (PCAOB), a private-sector, nonprofit corporation created to oversee the auditors of public companies in order to protect the interests of investors and further the public interest in the preparation of informative, fair, and independent audit reports.Evolution of Environmental Accounting StandardsThe common definition of "environmental accounting" is "the identification, measurement, and allocation of environmental costs, the integration of these environmental costs into business decisions, and the subsequent communication of the information to a company's stakeholders" (AICPA).Typical environmental costs include off-site waste disposal costs, cleanup costs, litigation costs, and other related costs.The first accounting standards or interpretation of standards that could be applied to environmental liabilities were enacted by the FASB in 1975 and 1976. These rules covered a generic grouping of contingent liabilities (including environmental liabilities). Initially the FASB stated that contingent liabilities arising from environmental cleanup costs should be accounted for and disclosed according to Statement of Financial Accounting Standards (SFAS) No. 5, "Accounting for Contingencies" (FASB 1975). One year later, the FASB issued Interpretation (FIN) No. 14, "Reasonable Estimation of the Amount of a Loss" (FASB 1976), offering additional guidance regarding loss contingencies. Essentially, the standard required losses to be accrued for when they became "probable and reasonably estimable."SFAS No. 5 is still followed today by accountants who are considering the measurement and disclosure of environmental liabilities.SuperfundPrior to Congress passing legislation granting the EPA authority to identify and sanction Potentially Responsible Parties (PRPs), most reported environmental liabilities were minimal. That changed in 1980 when Congress passed the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), commonly known as the Superfund Act. CERCLA established strict regulatory requirements regarding the release of hazardous substances from existing or future waste sites.Six years later, Congress amended CERCLA with the Superfund Amendment and Reauthorization Act (SARA).This strengthened the EPA’s authority and increased the agency’s fund balance. Under the new Superfund Act, the EPA became responsible for identifying and listing those locations throughout the United States where hazardous substances or waste either have caused or may cause damage to the environment. The EPA, through administrative or legal action, seeks to require PRPs to accept responsibility for the remediation of contaminated sites.Under CERCLA, a PRP is defined as any individual or company that is potentially responsible for, or contributed to, the contamination problems at a Superfund site. According to Paul D. Hutchinson, this can include:• Current owners or operators of facilities where hazardous substances have been deposited• Owners or operators of facilities at the time hazardous substances were deposited• Generators of hazardous substances deposited at facilities• Transporters of hazardous substances to facilities• Per sons who arranged for disposal or treatment of hazardous substances at facilitiesOnce the EPA identifies a PRP, a liability-based program is used to address the cleanup of the site. Under the liability-based program, a potentially responsible partyis classified into one of three categories:• Strict Liability - the PRP is liable for cleanup costs even when there was no negligence• Joint and Several Liability – any one party can be forced to bear the full cost of the remedy, even if several parties contributed to the waste at a site• Retroactive Liability - the provisions apply to actions that took place before CERCLA was passedAfter the EPA identifies the PRPs and their respective liability, it sends notification to the SEC and the respective companies or individuals.Regulation S-K and FRR 36With the increased environmental regulation, the accounting regulatory bodies began to issue standards regarding the reporting and disclosure of environmental liabilities. In 1982, the SEC integrated all of its environmental disclosure requirements into Regulation S-K, requiring disclosure if pollution expenditures had a material effect on the company's earnings. Regulation S-K Item 101, known as the Description of Business, requires registrants to disclose, among other things, the material effects of complying or failing to comply with environmental requirements on the capital expenditures, earnings, and competitive position of the registrant and its subsidiaries. S-K Item 103 requires registrants to describe any material concerning pending legal proceedings unless the legal proceedings involve ordinary routine litigation incidental to the business. S-K Item 303, often referred to as Management Discussion and Analysis of Financial Condition and Results of Operations, requires the disclosure of environmental contingencies that may reasonably have a material impact on net sales, revenue, or income from continuing operations.In 1989, the SEC provided further guidance by issuing Financial Reporting Release (FRR) 36. FRR 36 discusses and illustrates various disclosure requirements for the Management's Discussion and Analysis (MD&A) component of the SEC annual report 10-K filing and the shareholder annual report.Staff Accounting Bulletin (SAB) 92Even with this increase in regulation, companies were still finding it difficult toestimate liabilities that needed to be disclosed. In response, the SEC issued Staff Accounting Bulletin No.92 (SAB 92) to further clarify its disclosure requirements. SAB 92 specifically discussed the disclosure of environmental liabilities in the balance sheet. The SEC's position on the disclosure of environmental liabilities was strengthened through an agreement with the EPA in 1990. Essentially, the EPA would provide the SEC with certain quarterly information, including names of PRPs, a list of all cases filed under CERCLA, and a list of civil and criminal cases under federal environmental laws. In exchange for this information, the SEC agreed to target the enforcement of environmental disclosures.AICPA Statement of Position 96-1By 1996, the EPA had identified more than 36,000 hazardous waste sites in the United States. The EPA then took what they considered to be the most severe of the contaminated sites and developed the National Priorities List (NPL). This list contained 1,405 sites, each referred to as a Superfund site. From these Superfund sites alone, the EPA proceeded to identify 15,000 PRPs connected to these sites. These PRPs would eventually be responsible for cleanup costs that would range from $35 million to $1 billion per site. The release of this information revealed to the accounting profession that the remedial liabilities of the PRPs were significant and, therefore, required better accounting and disclosure. As a result, the AICPA issued Statement of Position (SOP) 96-1, "Environmental Remediation Liabilities," which provided specific guidance on estimation and the financial reporting of environmental accruals and contingencies.Analysis of the Standards (Past and Present)(A) Recognition of Environmental LiabilitiesRecognition pertains to when a liability should be reported in the financial statements. Contingent liabilities are obligations that are dependent upon the occurrence or nonoccurrence of one or more future events to confirm the amount payable, the payee, the date payable or its existence. The most significant liability that a firm faces in relation to environmental accounting comprises the remediation costs. Remediation costs typically include cleanup costs, litigation costs, and other costsassociated with legal compliance.FAS No. 5,mentioned earlier,requires that a provision for a loss contingency be recorded and a liability recognized in financial statements when both of the following conditions are met:• It is probable that an asset has been impaired or a liability has been incurred at the date of the financial statements• The amount of the loss can be reasonably estimatedFASB Interpretation (FIN) No. 14 provides additional guidance on how to recognize a loss contingency when the estimated loss is within a specified range. It recommends that the minimum amount of the range be accrued, unless some amount within the range appears at the time to be a better estimate than any other amount within the range.The AICPA SOP 96-1 expands the types of costs that may be appropriately accrued and the ability to consider technologies under development in order to help assess the ultimate cost of remediation efforts more accurately. PRPs must now use a more conservative approach (increase the probability of loss recognition) than under the prior provisions of SFAS No. 5 to ascertain if they should accrue such liabilities. According to the SOP 96-1, the probability criterion of SFAS No. 5 is met if the EPA has decided (or probably will) that the company must participate in remediation. Liabilities must now be recognized when litigation has commenced or an assertion of a claim is probable whenever the PRP is associated with that site. In addition, PRPs must now accrue potential environmental remediation liabilities "up front," all at once, rather than recognize the expenses when they are actually paid.(B) Accounting for Recognized Environmental LiabilitiesWhen a company has determined that an environmental obligation exists, it must be measured and accounted for based on available information. Key accounting issues related to the recognition of environmental liabilities are highlighted below: Estimates of the Environmental LiabilityAccording to AlCPA's SOP 96-1, once a liability is determined, its magnitude must be estimated. In developing the estimates, according to Kathleen BlackburnHethcox, Richard Riley, and Jan R. Williams writing in National Public Accountant, the factors below should be considered:• The extent and type of haz ardous substances at the site, and the costs to be included in the estimate• The effect of expected future events or developments• The range of technologies that can be used in remediation• The number and financial condition of other PRPs• The effect o f potential recoveriesEarly estimates of loss can be revised later if new information gives cause for a change. The revisions should be accounted for as a change in accounting estimate, thereby only affecting current and future financial reporting. No retroactive restatement of prior year financial statements is allowed under SOP 96-1. The SOP 96-1 also recommends that for various stages of remediation, benchmarks be used to evaluate the extent of the amount that can be estimated. At a minimum, the estimate should be evaluated as each benchmark occurs; which includes identification of the company as a PRP, receipt of a unilateral administrative order requiring a removal action, participation in a remedial investigation (Rl) or feasibility study (FS) as a PRP, completion of a feasibility study, and issuance of a record of decision.Source: Brian B Stanko, Erin Brogan, Erin Alexander, and Josephine Choy-Mee Chay.Environmental Accounting[J]. Buinese & Economic Review, 2006,(4):21-27.。