Do Environmental Consultants Have to be Licensed? Not in Michigan!

You have to be licensed through Michigan’s office of Licensing and Regulatory Affairs (LARA) to cut hair or install a drinking water well. While we’ve all had bad haircuts, it isn’t as likely to have a well installed improperly by a licensed well driller. It may be surprising to some, but Michigan does not license environmental consultants.

It would seem safe to assume that environmental consultants would have to be licensed since they conduct Phase I environmental site assessments (ESA) to evaluate the history of a property on behalf of buyers of property and lenders; conduct Phase II ESAs and site investigations to evaluate how much contamination is present; and complete remediation to cleanup contamination.  This is some pretty important stuff since you don’t want to buy a contaminated property without knowing it or pay to cleanup contamination and find out the cleanup wasn’t done right.

What if you hired an environmental consultant to conduct a Phase I ESA when purchasing property and they missed that the property used to be a dry cleaners, which contaminated the soil and groundwater?  What if you hired a licensed well driller who relied upon the Phase I ESA from the unlicensed environmental consultant, to install a water well at that property that turned out to be contaminated?  What if you hired an environmental consultant to complete a site investigation to delineate the extent of contamination and then cleanup that contamination, later to find out that the site investigation was completed improperly and the remediation technology didn’t work?  None of us would be happy with the scenarios described above, right?  Unfortunately, this is the current reality in Michigan and the above scenarios sometimes happen. 

Many other states including Illinois, Indiana, Kentucky, Ohio and Tennessee require licensed professional engineers (P.E.s), registered professional geologists (P.G.s), or other state specific licensing such as Ohio’s Certified Professional (CP), to be actively involved with environmental projects and to “sign off” on reports attesting to the accuracy and adequacy.  Shouldn’t Michigan have a similar requirement?

Part 213 (Section 324.21325 of NREPA Public Act 451 of 1994, as amended) requires that Qualified Consultants (QCs) perform the environmental work at leaking underground storage tank (LUST) sites. The MDEQ used to oversee the QC program; however, for various reasons (i.e. budget and staff shortfalls and the fact that this type of program is usually handled by other government licensing agencies such as LARA) their oversight of the QC program was eliminated.

Unfortunately, MPA Environmental Issues Committee (EIC) members and the MDEQ have reported more instances of people/companies who would not meet the QC requirements providing services at LUST sites.  This is a potentially dangerous situation and could result in work that won’t be accepted or have to be redone.

I’ve been working as a QC in Michigan for over 20 years and the environmental requirements are as technically complex as they have ever been.  It is nearly impossible to have the knowledge base and experience without a team of environmental professionals, which not all firms have.

Engineers and Geologists are the environmental professionals who receive the educational training and who can become licensed.  It seems that they should be the ones responsible for the proper assessment, investigation and cleanup of contamination and that Michigan should have environmental consultant licensing requiring P.E.s and/or P.G.s be involved with environmental project.

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January 13, 2016

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