Lessons Learned Addressing Contaminants of Emerging Concern at Federal Facility Cleanups: August 2024 ASTSWMO Report

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) released an August 2024 report titled:

Lessons Learned Addressing Contaminants of Emerging Concern at Federal Facility Cleanups (“Report”).

The Report was prepared by the State Federal Coordination Focus Group/Federal Facilities Subcommittee of ASTSWMO.

ASTSWMO describes itself as representing 50 states, 5 territories, and the District of Columbia whose mission is to enhance and promote effective state and territorial programs and to affect relevant national policies for waste and materials management, environmentally sustainable practices, and environmental restoration.

Matt Carey, P.G., who serves as a Geologist Supervisor in the Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”), Office of Land Resources is a member of the Federal Facilities Subcommittee. Blake Wittle, who serves as a Groundwater Manager in the DEQ Office of Land Resources, is noted to have participated in the development of the Report.

A contaminant of emerging concern (“CEC”) is sometimes described as a chemical or material characterized by a perceived, potential, or real threat to human health and the environment or by a lack of published health standards. A contaminant may also be “emerging” because of the discovery of a new source or a new pathway to humans. It can include diverse compounds classified as emerging because they are often newly identified manufactured or naturally occurring chemicals that are detected in various matrices at insignificant levels. Newer analytical capabilities are allowing the identification of chemicals in the environment in extremely low concentrations.

The key components of the Report include:

  • Regulatory frameworks.
  • State Involvement.
  • Incorporating evolving science into government regulations and policies.
  • Varied sources, processes, and findings in research.
  • Risk communication.
  • Conclusion and recommendations.
    • Proactive is better than reactive.
    • Develop proactive frameworks to address contaminants of emergency concern before the need arises.
    • Maintain transparency in community engagement for proper risk communication.
    • Stakeholders should not assume contaminants of emerging concern behave the same as other contaminants.

A copy of the Report can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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