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Recognized Environmental Professionals (REPs) will replace Individual Listed Consultants effective January 1, 2018. Existing Listed Consultants will be identified as such through that time. Prospective REPs will need to have an approved application and pass a regulatory proficiency examination to become a REP.
The purpose of the REP designation is to better align decision-making responsibility between OPS, environmental consultants and responsible parties by identifying environmental consultants who can demonstrate decision-making experience on releases to the environment.
Listed companies will remain as such by virtue of having at least one REP. Responsible parties of confirmed releases must retain a listed company in order to seek reimbursement at the Reasonable Cost Guideline Consultant Labor Rates. A REP within that company must be identified as the environmental professional of record associated with the confirmed release. This distinction is transferable.
The REP of record will be responsible for:
Signing off on submitted reports (i.e., characterization reports, corrective action reports and data evaluation monitoring reports) related to the assessment and progress of the release conditions.
Decision-making as it relates to assessment, cleanup, project progress toward regulatory endpoints, budget development and budget management.
Communication of regulatory deadlines to both the responsible party and OPS should an issue be identified by the REP.
The five primary attributes that an individual must adequately demonstrate to be considered as a REP are:
Appropriate educational background
Total professional experience
These attributes are evaluated through an application and examination.
A B.S. or higher in the fields of engineering, industrial hygiene or biological, chemical, environmental or physical science is required. An alternate track of fifteen years of total professional experience and eight years of decision-making experience may also be considered in lieu of the standard track educational background.
Professional judgment is expected to conform to technical standards.
Applicants must clearly demonstrate that they were principal decision makers on specific technical projects involving site assessment, risk characterization and remediation. Applicants will need to demonstrate five years of decision-making experience for the standard track. Decision-making experience is defined as experience that is demonstrative of a concurrent combination of environmental decision-making experience and practical experience, both performed with proficiency.
Applicants will need to demonstrate eight years of total professional experience for the standard track. Total professional experience is defined as experience applying scientific or engineering principles in the environmental, scientific or engineering fields where the resultant conclusions form the basis for reports, studies and other similar documents.
Applicants will be tested on their understanding of OPS statutes, regulations, guidance and forms.