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.

The Obama Administration announces new regulations on Dihydrogen Monoxide (DHMO)!

These regulations may prove to be the most significant regulations of the decade.   Environmental consultants see this as a huge new market.  I understand the EDR is will be creating a new product to help consultants understand where the DHMO risks are the greatest and I am trying to form an ASTM Task Group to explore a new standard that will address these regulations.

What is DHMO?

Dihydrogen Monoxide is a colorless and odorless chemical compound, also referred to by some as Dihydrogen Oxide, Hydrogen Hydroxide, Hydronium Hydroxide, or simply Hydric acid. Its basis is the highly reactive hydroxyl radical, a species shown to mutate DNA, denature proteins, disrupt cell membranes, and chemically alter critical neurotransmitters. The atomic components of DHMO are found in a number of caustic, explosive and poisonous compounds such as Sulfuric Acid, Nitroglycerine and Ethyl Alcohol.

Why we are concerned?

Each year, Dihydrogen Monoxide is a known causative component in many thousands of deaths and is a major contributor to millions upon millions of dollars in damage to property and the environment. Some of the known perils of Dihydrogen Monoxide are:

Despite the known dangers of DHMO, it continues to be used daily by industry, government, and even in private homes across the U.S. and worldwide. Some of the well-known uses of Dihydrogen Monoxide are:

• as an industrial solvent and coolant,
• in nuclear power plants,
• by the U.S. Navy in the propulsion systems of some older vessels,
• by elite athletes to improve performance,
• in the production of Styrofoam,
• in biological and chemical weapons manufacture,
• in the development of genetically engineering crops and animals,
• as a spray-on fire suppressant and retardant,
• in so-called "family planning" or "reproductive health" clinics,
• as a major ingredient in many home-brewed bombs,
• as a byproduct of hydrocarbon combustion in furnaces and air conditioning compressor operation,
• in cult rituals,
• by the Church of Scientology on their members and their members' families (although surprisingly, many members recently have contacted DHMO.org to vehemently deny such use),
• by both the KKK and the NAACP during rallies and marches,
• by members of Congress who are under investigation for financial corruption and inappropriate IM behavior,
• by the clientele at a number of bath houses in New York City and San Francisco,
• historically, in Hitler's death camps in *** Germany, and in prisons in Turkey, Serbia, Croatia, Libya, Iraq and Iran,
• in World War II prison camps in Japan, and in prisons in China, for various forms of torture,
• during many recent religious and ethnic wars in the Middle East,
• by many terrorist organizations including al Quaeda,
• by the semi-divine King Bhumibol of Thailand and his many devoted young working girls in Bangkok,
• by the British Chiropractic Association and the purveyors of the bogus treatments that the BCA promotes,
• by commodities giant Trafigura in their well-publicized and widely-known toxic-waste dumping activities in Ivory Coast,
• in animal research laboratories, and
• in pesticide production and distribution.

If you are interested in participating in the ASTM work group please email me at joe@partneresi.com.

What is the industry standard name for a Phase II?  Candidate names:  Phase II Environmental Site Assessment, Phase II Subsurface Investigation, Phase II Environmental Testing, Soil Testing?     Does it even matter?   Well, perhaps not much, but I think we are better off to use a common vocabulary.

According to ASTM E1903-97 (2002), Phase IIs are called, “Phase II Environmental Site Assessment “ and are conducted “to evaluate the recognized environmental conditions identified in the Phase I ESA or transaction screen process for the purpose of providing sufficient information regarding the nature and extent of contamination to assist in making informed business decisions about the property; and where applicable, providing the level of knowledge necessary to satisfy the innocent purchaser defense under CERCLA”.

I prefer the term Phase II Subsurface Investigation over Phase II Environmental Site Assessment as Phase I ESAs and Phase IIs are very different scope of work.   I like to give simple definitions to clients:  a Phase I ESA is basically all the reasonable research that you can do on a site; a Phase II is drilling holes in the ground.  

Can asbestos testing, indoor air testing, or stormwater testing qualify as a Phase II?   These activities are often done as a follow-up to a Phase I and I have seen these activities called a Phase II; however, I think no.   Our clients would be mislead if we called these activities as Phase IIs—call them something else.

What do you think?  Am I on the right track? 

This year I think half of the Phase I Environmental Audits that I do are on properties queued for foreclosure.  The Phase I Environmental Audits must meet the ASTM Standard 1527-2007, but in a foreclosure environment there are a few differences.  

First, most clients want the Phase I Environmental Audit to be completely AAI compliant.  To save our clients a few bucks, sometimes we do not order an environmental lien in favor of reviewing a preliminary title report. But, when a lender is taking title to a property the Phase I Environmental Audit should be completely AAI compliant with no limitations.

During a foreclosure, the borrower is not exactly excited about the process.   Often the site contact does not cooperate or is completely recalcitrant.   Sometimes our inspectors get shined at the site visit. Using an environmental firm with a local environmental site inspector helps mitigate this problem.  If the inspector had to fly to the site, then the firm may try to pass extra costs on to their clients.  Ask your consultant for a coverage map.

Finally, lenders often want to know what kind of shape their asset is now.   Often the appraiser will need a Property Condition Assessment Report in order to deliver a value.    The Property Condition Assessment Report also helps when selling the property.

The debate has raged through our profession for years.  Finally, the USGS has settled the issue:  groundwater is one word. 

It has been a longstanding practice within the USGS to spell ground water as two words and to hyphenate when ground water is used as a modifier (e.g., ground-water hydrology). Ground Water Branch Technical Memorandum 75.03 (http://water.usgs.gov/admin/memo/GW/gw75.03.html) issued just under 35 years ago specified that the two-word form should be used.

Language evolves, and it is clear that the one-word spelling of groundwater has become the preferred usage both nationally and internationally. The one-word spelling has been used by the Merriam-Webster online dictionary since 1998. Most water-resources publications also use the one-word spelling, as do many technical groups, such as the National Research Council. With the emphasis on interdisciplinary science, many USGS scientists who are not specialists in the field commonly use the one-word form, as increasingly do many hydrologists within the Water Resources Discipline.

The term surface water has not seen the same language simplification that has occurred with the term “groundwater.” “Surface water” continues in the English language universally spelled as two words. Use of the two terms together spelled as “groundwater and surface water” has become common usage.

With this memorandum, we are making a transition to the use of groundwater as one word in USGS. Changeover to use of the one-word spelling in our publications and web sites will be accomplished as seamlessly as possible. Reports in preparation should be converted to the one-word spelling where this does not require a special effort. Reports submitted for approval after August 1, 2009, will be expected to use the one-word form. During this transition period, the one-word or two-word spelling should be used consistently throughout a publication.

With this settled our government can get down to the rest of the country's problems.