
Hypothetical situation: You've been retained to conduct a Phase I on a property that, so far as you know upon taking the assignment, has been a warehouse for as long as your contacts remember. But upon reviewing historical Sanborn maps, you realize that prior to 1955 the property housed a leather-tanning and leather-goods manufacturing operation. You are not experienced in the manufacturing processes relating to tanning or leather-goods manufacture, and no one else in your firm has such experience. However, your most hated competitor has someone on staff who, you happen to know, has done extensive work in that industry.
What do you do?
A. Muddle through the best you can on your own; after all, you were awarded the contract.
B. Seek subconsulting assistance from the hated competitor (knowing there isn't enough budget to avoid a loss on the job if you do).
C. Go to your client and advise him that it might be best to terminate the contract and work with your competitor.
D. Other (please elaborate).
Comment
First I'd rely on my 15+ years of experience and the 100+ years of experience the senior people in my firm have doing ESAs. You don't have to be an expert in leather tanning to have a good idea of how often leather tanning is identified as a REC or shows up as an issue in regulatory database review. I'd then probably google "history of leather tanning" and "leather tanning process" and "leather tanning chemicals". Spend an hour or two reading up on leather tanning. Perhaps even ask here at CommonGround. Then I'd discuss it with the client, and make a decision. Not that complicated.
So I guess that's A. I can't think of any situation where I'd do B or C at the Phase 1 level. Not because I'm cheap or afraid of losing business, but because I can't imagine any situation where it would be necessary.
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I'd go with Matt on this one. One of the great things about Phase I's is that you will encounter new situations occassionally. I've found that a phone call to the Department of Environmental Quality (or Protection) will get some good information on the typical contaminants and process of a particular industry.
In this case, you can find in a few minutes that chromium contamination (among others) is associated with tanning by doing a search online. Already, I'm leaning toward a REC.
Like Matt, I can't imagine a circumstance where I wouldn't accept a Phase I for a reasonable price.
What would you discuss with the client Matt? Your findings after issuing the report, or what ongoing research is revealing?
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Whenever I find an environmental concern (REC or not), I'll discuss with client before issuing my report just to make sure we're all on the same page with sensitivities and recommendations. Also prior reports often magically appear that address the concern.
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I agree with Matt too. I'm not an environmental consultant, but it seems like there's no need to go to a "hated competitor."
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I would say "A", but I would not use the word "Muddle". Any good EP wouldn't think twice about researching a potential issue; it's what we do. In today's electronic world information too accessible to not research a concern.
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Google and Wikipedia are your friends. Be a lifelong learner. I'd rather gargle with fish puke than hire a "hated" competitor to consult on the tanning industry. Tanning is not rocket science nor are most things you'll encounter on your Phase I site visits.
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Interesting comments, everyone; thanks!
For future reference, there are a few publications that are particularly helpful in understanding historical industrial processes and their possible impacts on the environment. These include:
Research through these (including older editions if you can find them) will help the environmental professional to better understand the processes used by the industry in question, which in turn will provide guidance as to where one should look for problems, and what the nature of those problems may be. As Stones points out, Google and Wikipedia can also help, but for older facilities the available information may not have been updated in online sources.
Good luck to all when encountering a "new" industry to study.
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Lots of good references here also.
http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/
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I'd do it myself, really. I can learn enough about an industry in a couple days to satisfy my needs for a Phase I.
I like the EPA notebook thing, especially the printers and dry cleaners ones. You can also get quite a lot from history books, or even How It's Made or Dirty Jobs. If it was a large or long-lived company, someone may have done a company history.
Your usual COCs for tanneries are metals (most commonly arsenic and chromium, but others too). If it's not in an urban area, there may be burial pits on the site in which they disposed of wastes. Acids and caustics were used pretty intensely to defat and depilate the hides, but those aren't usually persistent in the environment. Dyes were usually vegetable-based prior to the anilines becoming common in the early 1900s.
Different types of leather involved slightly different processes.... e.g. saddle leather vs. patent leather (black and shiny, with a lacquer coating).
Random trivia-- the "soft, Cornithian" leather used in the first model years of the 1970s Chrysler Cordoba was apparently prone to giving people rashes because it was treated with large amounts of chromium and nickel. Thank you, Ricardo Montalban.
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Option A is probably fine if for purposes of the phase I - it’s simple enough to find the info necessary to conclude whether an unfamiliar operation should be classified as a REC. If the client isn’t asking for recommendations or asking you to decide the scope of phase II work, then that’s probably good enough. Once you move beyond the Phase I, though, I’d be reluctant to rely on a few days of research as assurance that I’ve adequately protected my client’s interest. I probably still wouldn’t want to bring in the hated rival, but there should be experts in the electronic community who can participate in Phase II design and review to improve the quality of the work without ever leaving their desks. The same could apply if you aren't confident of your phase I conclusion. Sharing your profit, or even losing a little on the phase I, is a small price to pay for the peace of mind.
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