EP 1110-3-8
9 Apr 04
4-17. Audit Procedures.
a. The documents comprising the Administrative Record file will be subject to audit and
therefore will be maintained as outlined in this EP. The purpose of an internal management
control review is to identify, report, and make appropriate recommendations regarding the
elimination of deficiencies in the establishment and/or maintenance of the Administrative
Record. The internal review will protect the interests of the Army in the event that the
Administrative Record is subject to review or audit. Further, the audit is necessary to ensure that
the Administrative Record is maintained in proper order when subject to judicial review. As
stated in paragraph 4-3, since judicial review of issues concerning adequacy of any response
action is limited to the Administrative Record, it is imperative that internal reviews be performed
to ensure the quality and completeness of each Record. The review may be performed by the
ARC when applicable or by an internal management control monitor for the HTRW and MMR
programs.
b. A system of internal controls will be established at each FUDS project to monitor the
Administrative Record process. To aid in the review, the following internal management control
checklist should be used. Inadequate procedures or incomplete documentation will be detected
by using the checklist, thereby preparing the FUDS project for an audit. This checklist can be
used for routine internal examination or by an external auditor.
Internal Management Control Checklist
(1) Is EP 1110-3-8 being used, for FUDS HTRW and MMR projects, in your
organization?
(2) Is an individual appointed ARC in writing?
(3) Are the documents created in the permanent Project File arranged according to the
Model Permanent Project File Structure, appendix J of EP 1110-3-8?
(4) Are all required documents included in the Administrative Record, as described in
appendix K of EP 1110-3-8?
(5) Does the Administrative Record have a Table of Contents?
(6) Does the Administrative Record have an Index? Does the Index indicate where the
documents are publicly accessible?
(7) Is the Administrative Record contained in 3-ring binders or other fastening folder
which secures all pages?
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