Our goal for environmental compliance is simple: zero deviations from regulatory standards and sound environmental practice. The goal of our Environmental Management System is to correct conditions that could lead to a violation before the violation happens. We have not yet achieved our goal of zero violations, but we continue to take every departure from regulations, no matter how small, very seriously.
The figure below charts our year-over-year performance — from 2009 through 2015 — with respect to environmental notices of violation (NOVs)1 received. In 2014, when we saw an increase in NOVs, we redoubled our efforts to emphasize compliance. With Board oversight, we initiated a third-party assessment of opportunities to enhance our compliance program, and we began a series of articles in our internal company newsletter on critical aspects of compliance with all applicable law and Waste Management internal policies.
1 NOVs may be given for anything from a short delay in receipt of a required report to a deviation from any aspect of regulatory standards or permit conditions. Some violations could have the potential to impact the environment, but most do not. Upon investigation, not all NOVs are ultimately found to represent an actionable violation.