The Cost of Non-Compliance | Part 1: Introduction

April 4th, 2023 | , , ,


Uriah Donaldson presented a technical paper at the 2023 IIAR Conference titled The Cost of Non-Compliance: An Objective Analysis of Federal EPA’s Enforcement at Ammonia Refrigeration Facilities. This blog series includes excerpts from his technical paper.

Part 1: Introduction

This paper presents an objective analysis of the Federal Environmental Protection Agency’s (EPA’s) enforcement of ammonia refrigeration facilities across America conducted using hundreds of publicly available independent inspection reports dating from 2006 through 2021. This paper is divided into three main sections. Section 1 presents a historical review of major events and environmental disasters that resulted in the Federal EPA’s formation and highlights the subsequent regulations developed by the EPA that apply to ammonia refrigeration facilities. Section 2 explains how the EPA calculates civil penalties. Finally, section 3 presents an analysis of the collected inspection reports, detailing trends in common findings, differences in the types of settlement agreements, and penalties.


This blog is the first blog of a ten part blog series that will be posted on our website over the next several weeks.

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