Beyond Compliance: A Call for EPA Recognition of Voluntary Efforts to Reduce Pollution

June 1991
Citation:
21
ELR 10305
Issue
6
Author
John A. Pendergrass III

There are an estimated six million work places1 and hundreds of thousands, if not millions, of pollution sources in the United States. It is impossible for the Environmental Protection Agency (EPA or the Agency) or the Occupational Safety and Health Administration (OSHA) to inspect every pollution source or workplace.

Voluntary compliance is the bedrock of regulatory laws in the United States, from traffic laws to tax collection to health, safety, and environmental regulations. Enforcement by citation is a deterrent to noncompliance. The general deterrent effect enforcement has on others in the regulated community is more valuable than punishing the individual violator.

John A. Pendergrass is President and Chief Executive Officer of NuCor Health, Inc., and Pendergrass Associates, both occupational health, safety, and environmental control services companies. He served as Assistant Secretary of Labor for the Occupational Safety and Health Administration after practicing industrial hygiene, toxicology, health physics and safety in industry for 35 years. He is a certified industrial hygienist (CIH), certified safety professional (CSP), and registered professional engineer (PE).

John A. Pendergrass III is a Senior Attorney at the Environmental Law Institute in Washington, D.C. Prior to joining ELI he was a Visiting Assistant Professor of Law at Illinois Institute of Technology Chicago-Kent College of Law. He was also in private practice with DeWitt, Sundby, Huggett, Schumacher, & Morgan in Madison, Wisconsin, and was an Attorney Advisor in the Solicitor's Office of the Department of the Interior.

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Beyond Compliance: A Call for EPA Recognition of Voluntary Efforts to Reduce Pollution

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