Lack of regulatory knowledge leads to environmental non-compliance

A study conducted by the EPA and the Chemical Manufacturers Association has identified six root and four contributing causes of environmental non-compliance.

Emphasising that 94% of the non-compliance events involved multiple causes, The Root Cause Analysis Pilot Project ranked causes in order of freqency.

The root causes of non-compliance were identified as:

• Facility unaware of applicability of a regulation
• Human error
• Operating procedure not followed
• Problems with the design or installation of equipment
• Circumstances involving contracted services such as hauliers or handlers
• Communication failures between facility and regulatory agencies

The contributing causes of non-compliance were identified as:

• Management’s failure to identify environmental aspects of facility process and operations
• Unclear reporting or notification procedures in place
• Contradictory interpretation of state or federal regulations
• Insufficient audit programme and failure to conduct routine site and equipment checks