The experiment was successful.  Seventeen state programs were reviewed against the standards.  Those states represented over 90% of the domestic onshore oil and gas wells and production.  Each of those states volunteered for review.  All seventeen states took steps to implement recommended improvements.  This resulted in protection and improvement of the environment.

Numerous people viewed the process as a success.  In 1995, a Presidential Task Force recognized the state review process as a model for state-federal interaction.  EPA praised the program, calling it a non-regulatory approach to solutions that protect the environment without posing undue burdens on industry or excessive requirements for states.  IOGCC characterized the process as one of the most important projects it has undertaken.  Other nations expressed interest in the process, so the revised guidelines were translated and published in Russian and Spanish.

But, in late 1994 and 1995, the state review process began to experience difficulties.  A number of things happened that, in themselves, might not be considered major problems, but when viewed together explain the breakdown of the process.  After the Council on Regulatory Needs completed revision of the guidelines, the Council was disbanded.  This gave the impression to some stakeholders that the Council's work was finished and that subsequent updates and revisions to the guidelines would not occur.  Additionally, as is often the case with federal support after program start-up, in 1995 EPA decreased funding to IOGCC that supported the state reviews to $224,134. 

The resulting cost containment measures caused dissatisfaction among some stakeholders.  Also, as part of an effort to streamline the organization, IOGCC reorganized its committee structure.  That reorganization changed the State Review Committee to a subcommittee of the Environment and Safety Committee.  This resulted in at least a perception on the part of some stakeholders of decreased importance of the state review process. Communications between some stakeholders deteriorated, and rather than working to resolve differences or strengthen the process, people started pointing fingers of blame at each other.  As time went on, several people involved in the development of the process retired or moved on to other endeavors, and were replaced with new people who were not familiar with the development of the process. 

This resulted in a loss of institutional memory, particularly among the states and industry, regarding the reasons why the state review process was initiated and why it was important.  Some state and industry people felt confident that the exemption would continue unchallenged.  Some state regulators did not like their programs criticized and began to look at the state review process as a nuisance or a problem rather than an opportunity for improvement.  As a result of cuts in EPA funding, environmental stakeholders were unable to continue participation. 

In response, IOGCC scheduled state reviews without the environmental stakeholders that had been involved in the process.  EPA refused to participate in those reviews.  The process fell apart.  The state reviews ended in 1997.

Then a number of things happened.  An Ed Bradley news special on CBS publicized complaints from neighbors of a commercial E&P waste facility near Grand Bois, Louisiana.  During that special EPA Administrator Carol Browner said that Congress should close the RCRA exemption loophole, and that industry got a sweetheart deal.  There were related lawsuits and the jury actions.  Even though the industry may have won in the court of law, it did not fare as well in the court of public opinion.  Some state and federal officials called for revisiting the regulation of E&P waste.

While this was occurring, environmental representatives who were participants in the state review process began to pressure EPA to revisit the risks posed by oilfield wastes.  They reminded EPA that it had been 10 years since E&P wastes were reviewed and that additional data and new risk models are available.  The situation appeared similar in many ways as it appeared in the late 1980's.

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