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Companies that incorporate Total Quality Management into their operations are placing increased emphasis on identifying the root causes of deficiencies and problems. This is in keeping with the TQM principles identified by Deming in Out of the Crisis. Deming states that quality comes not from inspection or from management by objectives or results, but from improvements made in the process and products in order to meet customer needs. Deming's approach demands a shift in focus from addressing symptoms to addressing causes. In this article, environmental management audits are presented as the best means to assure that adequate management controls are in place to protect the company, its managers and its employees from penalties associated with civil and criminal enforcement actions.