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USEPA Releases COVID-19 Guidance for Continued Work at Contaminated Sites

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As the government has deemed work at contaminated sites “essential,” the United States Environmental Protection Agency (USEPA) has issued guidance to assist contractors and ensure the safety of workers at these sites. According to USEPA, the interim guidance focuses on decision-making at emergency response and longer-term cleanup sites where EPA is the lead agency or has direct oversight of, or responsibility for, the cleanup work. This includes, but is not limited to, Superfund cleanups, Resource Conservation and Recovery Act (RCRA) corrective actions, Toxic Substance and Control Act PCB cleanups, Oil Pollution Act spill responses, and Underground Storage Tank Program actions. In addition, EPA is sharing this guidance with states to take into consideration as they encounter similar issues at state-led RCRA cleanup sites. USEPA recommends that parties postpone in-person meetings, door-to-door visits, and other face-to-face interactions.

According to USEPA’s news release, as of the beginning of April, EPA has reduced or paused on-site construction work at approximately 34 EPA or PRP-led Superfund National Priority List sites, or 12% of all EPA sites with ongoing remedial actions, due to the evolving situation with COVID-19. Regions have decided and may continue to decide to reduce or suspend response actions at particular sites for the following or similar situations:

  • State, tribal, or local health officials have requested particular site operations or types of operations that would pertain to particular sites be suspended.
  • Site workers have tested positive for or exhibited symptoms of COVID-19.
  • Sites where there may be close interaction with high-risk groups or those under quarantine, such as work inside homes.
  • Sites where contractor field personnel are not able to work due to state, tribal, or local travel restrictions or medical quarantine.
  • Sites where social distancing is not possible.

The interim guidance can be found here.

Related Practices:   Environmental and Land Use

Related Attorney:   Frances B. Stella