On September 10, 2024, the LSPA sent our comments to MassDEP’s Bureau of Waste Site Cleanup (BWSC) as part of its public comment period on Risk Characterization Guidance, Chapters 6-10, Public Review Draft.

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’s Risk Assessors Subcommittee of the Regulations Committee 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. 

Read the LSPA’s cover letter and review our 6-page matrix of specific comments.

The LSPA had two overarching recommendations:  

• The draft document would benefit from a reorganization into (at least) two separate topics: Site Investigation and Risk Characterization.
• The draft document needs to acknowledge both the separate and intertwined roles and responsibilities of the LSP and the risk assessor in site investigation and risk characterization.

Many thanks to those members who sent in comments. A hearty thanks to Marie Rudiman, Technical Practices Committee Co-Chair who spearheaded this review. 

Check this MassDEP webpage regularly to read documents related to the 2024 MCP Amendments, including Updated Shortforms: Method 3 Human Health Risk Assessment (July 2, 2024) and Q&A on Climate Change (March 29, 2024).