Ms. Jines of Cal-EPA OEHHA presented the concept and status of development of the REA-II, Private Site Manager.

The REA-II (Private Site Manager) registration program is intended for project manager-level professionals who will be directing cleanup activities at state-lead sites administered under the Private Site Management Program of the Department of Toxic Substances Control. The intent of the REA-II registration is for the state to have a state-registered individual who can essentially take over lead for the state the cleanup activities. The program is based on one currently in effect in the state of Massachusetts.

Qualifications for the REA-II registration call for an environmental professional with at least 8 years professional environmental experience, and with 6 years experience/expertise in site investigation, assessment, and remediation. To qualify for the REA-II registration, the applicant must have managed or supervised scientific or engineering staff conducting multimedia investigations, assessments, and cleanup work.

The REA-II professional is intended to serve as an advocate of the State of California. OEHHA expects the individual to serve two clients: the State (first) and the project proponent (second). Essentially the decisions made by the REA-II professional must address the interests of the State first, and the project proponent second. The person cannot be an employee of a project proponent or responsible party, which includes industry, brownfield proponents, lending institutions, etc. that may have a vested interest in the outcome of the cleanup action. This limits REA-II professionals to either consultants or contract staffing. Payment of fees to the REA-II must be totally independent in the outcome of the project. These requirements are intended to minimize the potential for conflict of interest among the decisions being made by the REA-II bearing on the interests of the State of California versus the interests of the project proponent.

OEHHA will implement an auditing program of the REA-II professionals to ensure that the desired standard of performance is achieved with reasonable care and diligence.

Cost for the program to the State will be addressed through registration and renewal fees. The application fee is $125, while the annual fee is $500. This represents a $625 initial cost to become registered as an REA-II. Registration will be renewed every 5 years. Renewal will be contingent upon meeting the initial criteria for registration plus attaining a minimum of 30 units of continuing education during the preceding 5 years.

The REA-II program is based on Assembly Bill 1876, filed October 13, 1995. In order for the program to be implemented, draft regulations need to be developed and approved. As of October 23, 1997, the regulations have been drafted, but not submitted for approval. Ms. Jines expected that the regulations could be submitted at anytime. Ms. Jines was hoping that the regulations would go through an emergency review/approval process so that the program could be implemented by the end of the year. As such, the earliest that applications could be accepted would be January 1, 1998.

During Ms. Jines talk, meeting participants asked many questions and provided several suggestions. Some issues related to conflicts in language of guidance regarding qualifications of the professional. Other comments related to the cost of registration and whether the State expected a sufficient number of individuals to apply to fund the program. When a show of hands was asked of the meeting participants, less than half indicated an interest in pursing this registration.

The major issue addressed to Ms. Jines was the similarities and differences between the CHMM credential and the REA-II program. The initial registration criteria for the CHMM credential and the REA-II registration are similar: both require degreed individuals with specific experience in the hazardous materials management industries. The CHMM credential is broader in scope than the REA-II registration because site mitigation is only one aspect of the credential. Both the CHMM and REA-II require continuing education for recertification/registrations. However, the major difference is the CHMM certification examination which forces the CHMM applicant to demonstrate their knowledge in this field through the passing of a 3-hour exam, instead of presenting experience on an application form.

The bottom line for the REA-II registration is that it is applicable to a small segment of the environmental community, i.e., those who seek to manage the mitigation of State-lead sites as a consultant or contract employee. The registration will be expensive to maintain. Although OEHHA estimates that there are 3,000 sites in California that are applicable to this program, each of the sites will require a project proponent with sufficient capital to hire the independent REA-II to manage the site cleanup. All of us in this field will look at this program with interest over the next year to see how it is applied to meet the goals of the State of California.