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Topic

    AmyH
    EP opinions needed, please
    Topic posted August 19, 2009 by AmyHSuper Contributor, last edited January 19, 2012
    631 Views, 10 Comments
    Title:
    EP opinions needed, please
    Content:

    I'm still looking for more EPs to weigh in:

    Is EPA's current definition of 'environmental professional' adequate? Why or why not?

    Comment

    • lavajumper
      posted August 20, 2009 by lavajumperContributor

      I think the ability to, or maybe moreso a loophole, for an EP to determine that someone should be an EP, is a mistake.  People who do not have the experience or the correct background (understanding of chemistry and geology) can miss some things that should be a REC, or understate when reporting to an EP.  While I understand that some people would disagree from a budgeting standpoint (2 people to perform a site visit, sometimes requiring a senior person), I really see the need for requiring at least the current requirements, and possibly more.

    • MaxEng
      posted August 20, 2009 by MaxEngElite Contributor

      I don't have a problem with the current definition of an EP.  It doesn't guarantee the User will get a good-quality ESA, but no such definition will. 

    • lavajumper
      posted August 20, 2009 by lavajumperContributor

      The ability to "designate" an EP is the biggest issue that I see personally.  Walking a site that was probably more like sites were in the 1980s, a "designated" EP walked past a drum of TCE, and did not understand a vapor degreaser and notice the numerous floor drains around it, which ultimately fed to a large underground storage vault for oil/water. 

      Nothing will guarantee a quality Phase I, but at least if we do try to stick to more stringent standards, it will help the EP designation stand out a bit more than someone who is not.

    • Scott Hassler
      posted August 20, 2009 by Scott HasslerMember

      Our opinions are based on our experiences and background.  There is no substitute for experience in performance of ESAs.  That being said, the EP definition requires more representative experience for those persons that do not have relevant degres in a related science field or a professional certification/licensure.  I believe the definition of the EP is as good as it can get without requiring some standardized testing.  I do not see that happening in the near future.   

      • R Scott Powell
        posted August 20, 2009 by R Scott PowellElite Contributor

        Hope Scott... Hope.  If we all close our eyes, click our heals, and wish big, miracles happen... well in the least, it'll take a miracle for a standardized test to be required.  We can hope though.  As for lavajumper's comment below the following link goes to the conversation Larry and I had previously on testing.

         http://commonground.edrnet.com/posts/0e7f4d7ebd

        Seriously though, if we don't speak up nothing will change.  Let Amy's discussion here be one of many banners for change to come.  "Hail the AAI Revolution!"

        ... OK, so it's the end of a very long day, I need to go home.

        Scott

    • lavajumper
      posted August 20, 2009 by lavajumperContributor

      Sorry, I was mainly going off ASTM there.  But that being said, a person who is not an EP doing a site visit under the "supervision" of an EP (who is not onsite) really doesn't seem to get to the purpose of the AAI rule.

      I saw in previous post about the state certification and accrediation idea.  I think that would be a very good investment in our profession.

    • Scott J. Dahlgren
      posted August 21, 2009 by Scott J. DahlgrenContributor

      I like the EP definition as it is.

      As far as state accreditation goes, I think that is not a good idea.  Do not get me wrong, some sort of accreditation is good, but I have a background with asbestos and lead-based paint, and it is a pain in the rear to go to multiple training courses and refreshers covering the same content, because this state has a slightly different take on the asbestos or lead-based paint regulations.  This is pointless to me and it only seems that the states are looking for funding.  (I know that I will probably get comments about this, but I have done work in multiple states in the midwest, and regardless of the regulations, the work seems to go the same with just slightly different paperwork.  But I also understand the the states need money to run programs, but that is a whole different can of worms that I really do not want to go into).

      If accreditation is where we are going to go, and I think we should, I think that it should be on a Federal level only.

      That is my 2 cents.

    • lavajumper
      posted August 21, 2009 by lavajumperContributor

      I agree with you on the federal level only, because I too am in asbestos and have dealt with the same issues.  Different state programs are a large pain in the rear.

    • AmyH
      posted August 24, 2009 by AmyHSuper Contributor

      Thanks, all. I'm going to print your responses in ESA Report, EDR's Phase I newsletter. Please e-mail me if you DO NOT want your comments published.

    • Scott
      posted August 25, 2009 by ScottSuper Contributor

      I don't think it's adequate.  In my mind, there's no reason to expect that a PE or professional geologist should automatically qualify.  Sure, they have lots of education, but not every PE or PG has awareness of environmental issues.  Based on my experience, a relatively small percentage of them are truly able to complete a quality Phase I.

      I also don't like what I consider to be a loophole - the qualification of people with 10 years of experience.  I've seen a lot of totally inadequate reports prepared by people that have been generating totally inadequate reports for over 10 years.  Under the standard, they qualify based on experience - it doesn't matter that the product they produce is not AAI compliant and would be virtually useless to their client in the event of litigation.

      I really don't like the idea of creating yet another certification/training course that will no doubt be an additional and periodic expense, but I don't see any other way to control who can perform a truly compliant and defensible Phase I. We're already in a position where some states have certification requirements and adjacent states don't, and I don't know that any states have reciprocity.  There needs to be some sort of universal standard that can be applied across borders.