On June 5, 2024, the LSPA sent our comments to MassDEP’s Bureau of Waste Site Cleanup (BWSC) as part of its public comment periods on two draft guidance documents: 

• Risk Characterization Guidance, Chapters 1-5, Public Review Draft
• Interim Guidance on Implementing Activity and Use Limitations (Interim AUL Guidance) 

For both sets of comments the LSPA adhered to our typical process for collecting and submitting comments on draft documents:

• We solicited comments from LSPA membership at large;
• The LSPA Regulations Committee formed a focused subcommittee of practitioners who drafted a set of comments based on those submitted and those from subcommittee members; and
• Finally, the LSPA Board vetted the draft comments to develop a final matrix of comments document. 

Many thanks to those members who sent in comments. A hearty thank you to Marie Rudiman, Technical Practices Committee Co-Chair, and John Harvey, Regulations Committee Chair, who spearheaded the risk characterization and AUL reviews, respectively. It was truly a collaborative effort.

Click below to read the draft BWSC documents as well as the LSPA’s comments.

Risk Characterization Guidance, Chapters 1-5, Public Review Draft

LSPA comments on the draft Risk Characterization Guidance fall into three broad categories: 

• LSPA suggestions for reorganizing the structure and order of topics in the document, and suggestions for making the document easier to navigate;
• Areas that the LSPA feels need general clarification, where inconsistencies might need addressing, and where specific language changes might be more appropriate; and
• Areas where the LSPA thinks there are significant omissions from the draft guidance, or the draft guidance does not correspond to the experience of LSPs and other practitioners regarding the process of characterizing risk. 

Read the LSPA’s cover letter and review our 14-page matrix of specific comments.

Interim Guidance on Implementing Activity and Use Limitations (Interim AUL Guidance) 

Review the LSPA’s 5-page matrix of specific comments.

We invite you to contact Marie and John with any follow-up observations.