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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