WHY COMPANIES GO ASTRAY: CMA, EPA dig up root causes for violations of environmental laws by large facilities

As the result of a quite atypical collaboration, the Environmental Protection Agency and the Chemical Manufacturers Association (CMA) have found out why companies breach environmental regulations. The most frequently cited reasons were failure to understand the regulations and human error. The three-year Root Cause Analysis Pilot Project was initiated when EPA went to the chemical trade association seeking information on why companies break the law. Jamie Conrad, a senior counsel for CMA who worked on the project, says the association thought the undertaking was an excellent idea. "Historically, EPA had been addressing only the symptoms of violations, and here was an opportunity to find out what the causes are," Conrad explains. So, CMA prepared a survey and sent it to 50 member companies identified as being involved in noncriminal, federal enforcement actions between 1990 and 1995. A total of 27 companies, which had been cited for a total of 47 "noncompliance events," returned the survey. ...