- the measurement might have been contaminated
- a measurement might have been entered in the wrong file
- the wrong file might have been input (such as due to a small mistake in entering the file name)
- the measurement device might not have been tuned properly for the measurement
- the wrong sample might have been measured
- the measuring device might not be working properly, perhaps because it is being used in conditions it is not designed for
- some kinds of noise can smear readings by a large amount even if the probability is low ("1 in a million chances happen 9 times out of 10") -- a case where the noise "caused" the outlier in the sense you probably meant
- there might be additional processes at work that were not accounted for, and might not always occur, such as you might get a sudden spike in chemicals in water right as fish lay eggs
- some kinds of noise can trigger large reactions, where the reading of what actually happened might be pretty accurate but the large reaction does not occur much -- a case where the noise "caused" an actual change, which is probably not what you meant about causing outliers.