• Conducting ESA’s During a Pandemic

  • There is so much information, and some disinformation regarding the current Covid-19 virus pandemic, I thought it would be timely to discuss a few suggestions for conducting Environmental Site Assessments in these crazy times. I won’t elaborate on hand-washing, social distancing, staying at home, etc. as these are being hammered into us daily – and if you aren’t paying attention and practicing these vital measures, the most polite thing I can say is START NOW! The following articles will address some considerations and safer practices for completing your ESA. First off – make sure you fully comply with all the recommendations of your local public health authority and legal requirements in your jurisdiction; and don’t forget to WASH YOUR HANDS; SANITIZE; MAINTAIN PHYSICAL DISTANCING & STAY AT HOME! I think that should be pretty clear by now.

    Project Communication
    In Ontario, some consulting services like environmental rehabilitation, management and monitoring; and spill clean-up and response have been designated as ‘Essential” businesses which can, for now anyway, remain open during this pandemic. I don’t think this is the proper time for consultants and others to use this ‘essential’ designation as an advertising vehicle. This is a great responsibility, both to protect the public and the environment as we normally do; and to do it in a safe manner during this current pandemic. We should also be cognizant and empathetic that many other individuals and businesses are subject to forced closure and resulting economic hardship during this Corona virus pandemic.

    The health and safety of our staff, contractors, clients and other stakeholders is vitally important; and should take precedence over arbitrary deadlines for real estate transactions – and this needs to be understood by all involved before any project is initiated. If the ESA cannot be done safely under these conditions, or a job site or project is shut down by regulation or emergency order, then postpone it, or adjust your work program so that it can be done safely and legally. This may result in project limitations and other obstacles; which should also be communicated to all stakeholders.

    Records Review
    The requirements for records review are prescribed in CSA, ASTM and other guidance documents, and in some cases, more in depth research may be necessary to fully understand the history and potential environmental liabilities at a particular site. This may involve file review at municipal offices, local and university libraries, provincial and city archives, conservation authorities, and private data sources. You may need to examine building permits, aerial imagery, city directories and fire insurance maps; all of which may now be unavailable as many municipal offices and libraries are closed to the public. This lack of public access may necessitate using alternate information sources, including paid services such as ERIS databases, and online or in-house resources. You should be aware that some of these same data sources may also be unavailable to the large data companies. Expect possible delays to regulatory requests and Freedom of Information searches. These limitations and delays should be explained to the client and stakeholders at the start of the project and must be considered when formulating the conclusions of the ESA report.

    Site Visits
    Interior inspections of hospitals, long-term care, assisted living, and senior living facilities are likely to be prohibited. Multi-family property inspections should be modified to minimize contact and could be limited to vacant units and common areas. For all other sites, physical distancing should be maintained, and exterior-only access for low-risk sites is preferred. For environmentally intensive operations, determine if you can obtain interior access while maintaining social distancing. Check to see if there are localized lockdowns, travel restrictions or quarantines in place. When travelling to a site, or for remote sites, travelling in your own vehicle is preferable to a rental vehicle, or a company vehicle that may have been used by multiple people.

    Prior to the site visit, inform the Client and Site contacts of the expectations; including not shaking hands, wearing gloves, observing social distancing, and possibly conducting site visits during non-working hours to limit potential exposure to the virus. If interior access is necessary, plan the site visit in advance. If possible, have the site contact open all doors prior to arrival or during the inspection to minimize contact. If full access is impossible or restricted can alternative methods be employed (video, photos, alternate timing)? For some larger sites you may want to consider using drones to view portions of the site and study area.

    In some situations additional PPE than would normally be used may be required (e.g. Tyvek suits, full face masks, respirators). If so, you should communicate to the site contact that you will be donning them for protective measures, not because you are sick. Bring hand sanitizer to site inspections; wear disposable gloves, change them as needed, and be cautious of what you touch. Sanitize your field tools (i.e., pens, clipboards, cameras, vehicle, etc.) after use and before leaving the site. Take precautions to prevent bringing contamination back with you, and risking potential virus transmission to others. If you are doing a soil or groundwater investigation for a Phase Two ESA, you will require enhanced health and safety planning and project coordination. Implementation of best practices for drilling and sampling is needed to eliminate, or at very least to minimize physical contact between the field crew. Using a no-contact method to pick up supplies and deliver samples to the testing lab should be considered. If you need PPE or decontamination supplies, plan this well in advance as such products can be very hard to find these days.

    Interviews
    Try to avoid large groups and meetings in closed or cramped quarters for the inspection and interviews. I have always disliked conducting the ESA with a big group that includes the Site owner, the buyer, their respective realtors, the structural engineer, HVAC consultant, Site manager, and tenant representative(s); so now is perfect time to avoid this practice. Keep the group small, keep things concise and minimize excess time on Site. Although a personal interview is usually preferable to establish credentials and increase comfort levels in order to get better information; try to avoid in-person interviews, especially with multiple interviewees. We should recognize that some interviewees may not want to meet in person due to the perceived risks. Be creative. Try conducting interviews by phone, or Skype/Facetime/Zoom/Go-to-Meeting, etc.; or with pre-inspection e-mail questionnaires and follow up communications by phone or e-mail.

    Reporting
    As noted, pandemic conditions may impose limitations on your records review, interviews or site inspection. Be sure to thoroughly document these limitations and consider whether they will affect the findings, conclusions and recommendations. In some cases the impact may be minimal, or alternative resources or methods may be employed to reduce the significance of such restrictions. For other complex sites, severely restricted Site access or limits to available records could impose significant restraints in providing accurate, rational and defensible conclusions. In some cases this could necessitate completion of a Phase Two ESA to provide the client with an acceptable level of confidence regarding environmental conditions and potential liabilities. Make sure this is communicated to all involved stakeholders, prior to commencing the ESA and in your final report; and that everyone fully understands the implications and relevance of all such limitations.

    Next month I will discuss some tips on working from home efficiently while maintaining your sanity. In the meantime, stay safe, keep healthy, try to be positive, and look after each other. We’re all in this together, and together we will all get through it.

     

    Bill Leedham, P. Geo., CESA
    Bill is the Head Instructor and Course Developer for the Associated Environmental Site Assessors of Canada (
    www.aesac.ca); and the founder and President of Down 2 Earth Environmental Services Inc. You can contact Bill at info@down2earthenvironmental.ca