LSRPA Comments on Changes to Mandated LSRP Audit Procedure

In a letter dated September 8, 2017, to the NJ Site Remediation Professional Licensing Board (SRPLB), the LSRPA expressed concerns about proposed changes to the procedure for selection of LSRPs to be audited and requested the opportunity to address the SRPLB prior to action being taken. The agenda of the August 7, 2017 SRPLB meeting stated that the audit procedure would be modified “…to include a mixture of LSRPs picked randomly, and also identified on a non-random basis (i.e., numerous deficiencies in submissions, etc.).” In our correspondence and testimony to the SRPLB on September 11, 2017, it was noted that the LSRPA has worked cooperatively with the NJDEP Bureau of Inspections and Review (BIR) to identify and address issues encountered by both BIR and practicing LSRPs and pursuant to this, the LSRPA has been repeatedly told that NJDEP does not keep a list of LSRPs who have submitted deficient documents; this was confirmed by Assistant Commissioner Pedersen.
 
LSRPA emphasized that the NJDEP is responsible to identify deficiencies in the performance of the remediation, while the SRPLB is responsible to determine compliance with the Site Remediation Reform Act (SRRA) and any rule, regulation or order adopted or issued pursuant thereto. The LSRPA expressed grave concerns that the selection of LSRPs for audit based upon an unsubstantiated list of deficient submissions would results in an unacceptable bias to the SRPLB’s audit of LSRPs. We are anticipating a formal response from the SRPLB.

Click to View the Letter