Lack of regulatory knowledge leads to environmental non-compliance
Companies' lack of knowledge that their operations are subject to environmental regulations is the most common cause of 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
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