At their October 8, 2024, meeting, the LSP Board discussed the steps they are taking to prepare for administrative approval to release their proposed 309 CMR 1.00 -9.00, Regulations of the Board of Registration of Hazardous Waste Site Cleanup Professionals. There is not currently a specific timeframe for public review and comment on the proposed regulations, but the LSP Board shared preliminary documents including:

• Background and Technical Support Document, Draft Amendments, 309 CMR 1.00-9.00
• Regulatory Impact Assessment
• Outreach Plan

Provided below is a brief summary of proposed changes most pertinent to LSPs.

Reducing the Number of Credits Needed to Renew a License. The Board proposes to reduce the total number of continuing education (CE) credits required for an LSP to renew an LSP license every three years from 48 credits to 36 credits, and to reduce the required number of DEP credits an LSP must complete every three years from 12 to 9. The Board also proposes to reduce the number of CE credits needed to apply for a 90-day extension of the deadline for license renewal from 12 or fewer, to 9 or fewer of the required credits.

Simplifying the Types of Continuing Education Credits Needed to Renew. The Board proposes to simplify the types of CE credits required. Rather than the current three categories of credits (Regulatory, DEP, and Technical), the Board proposes to require an LSP to obtain a minimum of 9 DEP credits and the remainder in Non-DEP courses, eliminating the requirement to obtain Regulatory and Technical credits. 

Allowing Continuing Education Credits Earned Outside a Renewal Period to Count Toward Next Renewal In Some Situations. The Board proposes to allow LSPs to apply some credits earned outside a renewal period toward their next license renewal in some situations. For example, an LSP may apply up to 6 CE credits earned during the last six months of a license renewal period toward their next license renewal provided those credits were not applied to the LSP’s previous renewal. Other situations apply to LSPs with lapsed licenses; LSPs who have qualified for a 90-day extension; and applicants who have been approved to take the LSP examination. 

The Board also proposes updating the regulations to reflect new electronic opportunities, these include the recent introduction of an online portal for applicants and LSPs to submit documents, pay fees, and receive notices; and requirements for polling questions to ensure LSPs are present and engaged when taking online courses.