I think another area where EPA missed the boat on AAI was not requiring states to adopt licensing requirements for EPs.
Besides having incredibly low threshold for EP, a national licensing would have at least put the brakes on some of the bottom feeding going on that is causing the quality of reports to deterioate (unlike the braking problem with Toyotas-sorry couldnt resist) :)
One of the reasons we had a sub-prime problem was that unethical mortgage brokers were allowed to operate without any licensing and essentially were able to lie to unsophisticated borrowers about what the borrowers were agreeing to pay. While I am not accusing professionals who work at commodity-shops of being unethical, I do think that creating a sufficiently rigorous barrier to entry to help screen out the less motivated and unprofessional sorts would would look to another less demanding field that does not testing or licensing such as mortgage brokers. :)
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Don't assume a license will change anything. New York State has some of the most rigorous asbestos regulations in the country and yet we continue to see poor quality, cheating and excessive "add ons" in the asbestos field. What it does create is another level of work for the state regulators that can only go after the most grotesque violations; that is, the building demolitions with literally no asbestos surveys. (Yes, this still happens, one recently in downtown Buffalo.) The market has to fix itself. Don't let consultants get away with limiting their liability to the cost of a report and when they screw up, make them fix it. I see time and time again banks getting horrible reports; all they do is avoid that consultant in the future.
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I support national licensing. If the licensing requirements have enough rigger, then we will not see anyone with a computer thinking that they can do a AAI Phase I ESA.
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I am also supportive of national licensing. However, I also concur with the comments by MSA. Over the years, the worst quality reports to come across my desk have come from people who (at least according to their resumes), would absolutely meet even the most rigorous requirements for an EP. Poor reports are rejected and we move on, which I think echoes MSA's comment about the market fixing itself.
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