Common Sense, an Important Role in Environmental Due Diligence.

Check. Who doesn’t like putting this mark next to completed tasks? Most of us with busy schedules and multiple deadlines are looking for ways to streamline our processes, complete jobs faster, and get onto the next thing. In order to do so, we often follow procedures, standards, and well warn paths of repeated actions. In many ways this is valuable way to work. It allows for consistency and speed while delivering a predictable outcome. There are many tools that can help with this process including templates, report writers, and formatted attachments. If all goes well, another report is ready to fly-out-the-door in record time.

Environmental consultants commonly follow the ASTM 1527-13 for Phase I Environmental Site Assessments. The standard offers a guideline to collect and present data for assessing known or potential sources of oil and hazardous materials. Many environmental companies complete these assessments utilizing report writing technology and by purchasing packages of data to review and include in the appendices. This process is designed to be repeatable and in theory defensible. Given today’s Phase I pricing it allows authors to complete the report relatively quickly.

Environmental consultants also follow ASTM E1903 – 19 when completing Phase I Environmental Site Assessments – Subsurface Investigations. It provides a framework for objectives, scopes, sampling processes, analysis, and outcomes. It makes clear that it might take more than one sampling event to understand the environmental risks on a property. Once again, having a standardized format can be helpful to complete work on schedule and within a reasonable budget.

I have reviewed many reports missing one critical component, common sense, leading to reports that are confusing and incorrect. Many reports are rushed due to deadline pressure, limited budgets, and the comfort of a process. And the same reports make it through data compilers, authors, and senior reviewers while missing key points and failing to give the report user, the client, the information needed.

Reduce oversights by following these five steps.

  1. Have the author act like a scientist collecting all pertinent data and then think like a consultant interpreting the data to define the risk and offer client solutions.
  2. Take a step back and see how the results fit into the overall picture.
  3. Complete a simple online search for the Site address, tenant’s name, and/or other general property content.
  4. Check local regulations to confirm that report recommendations are necessary.
  5. Understand what the user is doing with the report’s information.

As a third-party reviewer, I frequently do not have access to report authors to ask them questions and to have them discuss the issues with me.  Therefore, I follow the steps above to understand and explain known and potential risks to clients.  By using common sense I make certain that the author:

  • did not miss any pertinent facts,
  • provides a defensible assessment given the data they present,
  • and provides conclusions and recommendations that are reasonable.

Common sense has an important role in environmental due diligence.