Monthly Archives: March 2012

Do you really know your consultant?

I came across a discussion panel in LinkedIn recently that was very interesting. There was this environmental consultant who was asking people questions like:

How do you prepare a Health and Safety Plan? Can someone send me a copy because I have to review a Health and Safety Plan for my client? I don’t know how to write a report. Can someone show me? He also posted on the same discussion panel his background which I show below unedited (bad grammar and all):

“I have MS in Environmental engineering. As far as experience,i dont have any,But i feel confident in doing this job. my company is a very small one with 7 employees.as far as training is concerned,no training is provided to me.i just have to review the previous reports,understand it and write a report based on the site conditions and other data.final correction is made by my boss before sending to the client”.

He asked a lot of questions but he never participated in any discussion of any kind. Why? Because he has neither the experience nor the knowledge to engage in any discussion. He is like a baby chick sitting in a nest with its mouth wide open waiting to be fed by his mother.

This recent college graduate works for an environmental consulting firm in New York and is being billed out as a Project Manager to the clients!

The teachable moment is this: Before you hire a consulting firm, insist on finding out who is going to be working on your project. Is it  going to be a recent graduate who has no experience? Is he going to be learning on the job at your expense? Or does the firm provide training to this employee. Many consulting firms will tell you that they will be assigning the best and brightest engineer to your project in their proposal to you. But as soon as you award the contract, you find out that it is a recent college graduate that is learning at your expense.

Always insist that the firm gets your written approval before they make any assignment changes in your project. Insist that you talk to that engineer directly.

On any given day you can find advertisement in the local newspapers or the Internet from large environmental consulting firms looking for “environmental professionals” with 0 to 2 years of experience.

Caveat emptor is the operative phrase here. Are you really getting what you are paying for?

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Is groundwater “navigable waters” under SPCC?

You have to prepared a SPCC plan if you have more than 1320 gallons in shell capacity AND the potential to impact navigable waters of the United States.

Many people ask the question” “Is groundwater included in the definition of navigable waters under the Spill Prevention Control Countermeasures regulation?”

The short answer is NO.

However, keep in mind that groundwater could act as a conduit for spilled oil to reach navigable waters of the U.S.

Here is what EPA stated in its SPCC Inspection Guide: Facilities should consider “certain underground features (e.g., power or cable lines, or groundwater), (that) could facilitate the transport of discharged oil off-site to navigable waters.”