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    JoeDerhake
    Environmental Professionals as Required by ASTM E1527
    Entry posted May 8, 2010 by JoeDerhakeSuper Contributor, last edited January 19, 2012
    2033 Views, 9 Comments
    Title:
    Environmental Professionals as Required by ASTM E1527
    Entry:

    There has been much discussion about the creation of a national environmental professional registration system and having a new ASTM Standard to require that a ‘Registered’ Environmental Professional conduct a Phase I Environmental Site Assessment (ESA).

    I support such a requirement, as Environmental Professionals too often have to compete with either non-professionals or professionals in a related profession who think that because they are engineers or geologists, they are qualified to complete a Phase I Environmental Site Assessment.  The fact is, performing a Phase I ESA well depends heavily on experience.  Experience is what you need to uncover the less than apparent, recognized environmental conditions; it is what makes the assessor ask the less than obvious questions.

    Now, I realize that there is much to work out on the subject of the environmental professional registration process.  Who will run such a program?  What will be the qualifications? Who will verify education and/or experience? Who will design the ‘test,’ if the registration includes passing a base test?   I am open to all reasonable proposals here, but I would like to offer my recommendations:

    Who would run the Environmental Professional Registration Program?

    I propose that the ASTM would run the National Environmental Professionals Registry Program.   The ASTM could likely charge a significant fee—good, this will serve as a barrier to entry.

    Qualifications?

    Qualifications should require a combination of experience, education, and test base registration.    A professional with a strong education and state registrations would require less experience.  An individual without as much education or registrations can still become an EP, but would require more experience.  Again, here is my proposal:

    To become an Environmental Professional, the person must meet one of the following:

    1)      A Registered Professional Engineer or a Registered Geologist with five years  experience in environmental consulting;

    2)      A bachelors in science in a related field from an accredited university with 5 years full time experience in environmental due diligence;

    3)      A bachelors in arts or a bachelors of science in an unrelated field from an accredited university with 7 years full time experience in environmental due diligence;

    4)      Have the equivalent of 15 years of full time relevant experience.

    My suggested qualifications are a bit more stringent than those currently incorporated in ASTM 1527.

    Keywords:
    Environmental Professional, ASTM 1527-05, ASTM Phase I

    Comment

    • mkulka
      posted May 9, 2010 by mkulkaElite Contributor

      I am not big on a BA and 7 years but at least they must have a bachelors which is better than the current 10 years and not have a GED.  I also think the requirements of proposed bullet 4. of 15 years experience and the BA plus 7 years should only be used as an initial registration for those practicing today who meet the requirement and could be grandfathered in during the first year (if this ever happened).  After that you could only meet EP by criteria 1-3 with a BS.   I openly acknowledge there are plenty of well qualified EPs that fall in the latter categories and deserve to meet the criteria.  This would encourage future environmental professionals that they must attain minimal educational requirements. 

      I think we should take it a step further and establish of continuing education requirements and a protocol where a minimum of 5 EPs must endorse a candidate similar to PG and PE licensing and registration.  This would instill a true vote of confidence and verification in a candidate.   The current honor system caters to the PGs, PEs or other non experienced alleged EPs you referenced above who do not really work in the field and failry compete with the practicing EPs.

       

      • Mike
        posted June 7, 2010 by MikeMember

        Regarding your last paragraph, I have my office in a city of around 50,000 people and believe it or not, there are only three EP's living in the area. In the process of producing Phase I ESA's for lenders, clients, etc., I rarely interface with other PE's outside my home city. In order to get the endorsement of two other PE"s, I'd have to go to someone I'd met at a professional meeting or on line. Neither of the two would have any real idea of my competence in conducting Phase I ESA's or any other areas an EP normally covers for that matter.

        Finally, this type of arrangement could quickly turn into an "I'll scratch your back if you scratch mine" event for those without integrity.

    • Lauren617
      posted May 12, 2010 by Lauren617Elite Contributor

      Interesting timing for your post, Joe.

      Many people probably know that the ASTM by-laws have, until recently, prohibited certifications standards. I attended the ASTM meetings in April and the chairman ASTM's board of directors came to the E50 Executive Committee meeting to announce that the board had recently voted to allow certification standards (of both products and personnel) within ASTM. They made this decision when a committee that writes standards on toy safety lobbied to create a safety certification for plastic toys.

      ASTM is going into this new area with some hesitation and the chairman let us know that they would not be pursuing certification programs proactively, but has made the change at the request of its members and to compete with other standard writing organizations that already allow for certification standards.  It was also noted that ASTM would not do the certification itself; instead it would work with third parties to do the actual testing of products/personnel. (In the toy safety example, ASTM will not keep plastic experts on their staff to do the analysis of the toys, they will partner with firms that already have this type of expertise.)

      In light of this development, the E1527 task group discussed the possibility of eventually creating an EP certification process, but there were a lot of reservations, one of the biggest being cost.

      It makes sense for ASTM to be the place where this certification happens, if it ever does happen. But I wonder if the industry would accept this. ASTM is a consensus organization, and I'm sure this would be an EXTREMELY hard standard to gain consensus on. I also wonder if the user community would appreciate certification process or if they'd be upset with the increased price in Phase Is that would likely result. What do you think?

      Should be interesting to see where this goes!

    • LSchnapf
      posted May 13, 2010 by LSchnapfElite Contributor

      I think it would help if EPs were required to do the site inspections and write the reports rather than just supervise the non-EPs. Under the current system it is like having a law student do the work and I sign the memo. Such a change could help weed out the phase 1 commodity shops and restore some pricing sanity to the market.

       

       

    • Mike
      posted June 1, 2010 by MikeMember

      There is already at least one national credentialing organization, the National Registry of Environmental Professionals (NREP), which offers a variety of certifications in various environmental fields, and one specifically tied to Phase I ESA's. Their certifications typically cost around $750 and include a closed book examination of at least a couple of hundred questions. If ASTM gets serious about this issue, and I am not at all sure ASTM should be in the business of certifying people, they should at least seek some type of continuity with NREP's certification.

      I've been conducting Phase I and II ESA's for over twenty years and it is my firm belief that on the job training is the best classroom. Assuming you've got a bright individual (one who learns quickly and is self motivated), no more than sixteen hours of class room time should be sufficient to begin working them in the field next to a seasoned professional. Secondly, so much of our work involves intuitive thinking, that individual should have that character trait as well. Unlike mechanical engineering, for instance, where one can plug numbers into formulas to get results, environmental consulting frequently required "out of the box" thinking (and I am not bashing engineers here - I love engineers because they have made my world safer and full of conveniences). What I am trying to say is that the apprentice time requirement is critical to becoming a better than good EP.

      The only real positive I came up with in thinking about this is that ASTM could get the jump on the EPA, but then I also thought that same thing about the well written ASTM Standard Practice E-1527-05. Had not a lot of members of ASTM and others raised hell, we would have had a standard written primarily by a cadre of academics who knew nothing of environmental site assessments.

    • ks
      posted June 4, 2010 by ksMember

      This is an issue that has been going around the block since the 80's.  It seems there has been a number of attempts at developing a professional credential for environmental professionals over the years - some have been valid attempts, and others were analogous to the "Cracker Jack" box.  Ultimately, they all failed to rise to the desired level or prestige initially sought.  While obtaining the credential involves education, experience, exams, and ethical commitments, it is simply just a membership to an industry group. 

      What these credentials lack is ANY legal authority on the state level, which is why the geologists and engineers excel in this arena. 

       

    • FStephenMasek
      posted June 6, 2010 by FStephenMasekContributor

      I participated in development of the ASTM PCA standard, and am participating in the discussions of the revision of E1527.  Many without a science/geology degree are very good at this kind of work, proving that such as degree is not necessary.  You just can never get past the fact that many people who do PCA, Phase I, and many other types of work very well have neither such educational backgrounds or licenses. 

       

    • LSchnapf
      posted June 7, 2010 by LSchnapfElite Contributor

      It is true that many without a science degree can exhibit sound judgment and even write better reports, However, the issue to me is to create stringent entry requirements that can help weed out the unmotivated and incompetents. Right now, it is almost as easy to be an EPs as a mortgage brokers.  I dont see any reason why we dont require EPs to be licensed like asbestos, LBP and mold inspectors.

       

      Larry@SchnapfLaw.com

    • ShannonSmith
      posted June 23, 2010 by ShannonSmithMember

      I agree that the EPs should be licensed. There are existing state programs that could provide a venue for licensing/certification.

      For example, in California, we have the Registered Environmental Assessor (REA) certification program. Currently, this is not a skills-based entry, but requires the sign-off of two or three other REAs to testify to the applicant's ability. The application process could be modified to include a skill assessment, similar to the CA certifications for asbestos sampling, etc., with the associated application fee increased to cover the cost of testing.

      I also agree that there should be a requirement for a bachelor's degree, but not necessarily a science degree or even B.S.. Many of the best EPs I work with (including myself) do not have B.S. degrees but our degrees (Environmental Studies, History, Law, etc.) have provided us with excellent training in critical thinking, historical research methods, and technical writing.

      The major components of the Phase I process (e.g., site visit, interviews, records review) have little need for an advanced understanding of engineering or geology. In my experience, there have not been many assessments where the conclusions of the report hinged on the soil type at the site (for example).

      I look forward to hearing more about this process.