|
supplement or go beyond the current laws relating to notice requirements for reportable releases ?
Another concern is that the proposed rule mandates the reporting entity to assess and establish what the pollution risks are and establish what precautions should be taken . Most companies do not have the expertise onhand to determine risk or necessary precautions , and we believe that task should fall upon the Department of Environmental Protection as is the current practice . Moreover , current notice requirements for reportable spills do not require notice to the media or mass communication .
The Honorable Jon Steverson , Secretary November 9 , 2016 Page Two
In addition , we believe the proposed rule shifts the focus for the regulated community to “ process ” when a spill occurs , rather than to clean-up of the incident . Businesses will be forced to establish the necessary expertise and costly infrastructure to locate and alert local public officials , local governments , property owners , the general public and the local media within
|
a 24-hour timeframe . For contractors and the construction industry , this would also include project owners , engineers , subcontractors , etc . Shouldn ’ t notifying the public and the media of risk and precautions of potential pollution hazards be the responsibility of the agency charged with “ environmental protection ?”
Furthermore , the notice provisions included within the rule need more clarity for the obligations identified within 24-hour period and the 48-hour notice requirement . Moreover , a known tenet of “ crisis management ” is that there should be one central clearinghouse for information and communication dissemination so that the management of information and misinformation can be accomplished without undue alarm to the public . We believe the department should serve as this information “ clearinghouse ,” especially as it relates to notifying the media , in an effort to limit conflicting messages .
In closing , I would ask that you provide additional , adequate time for review and comment on the proposed Pollution Notice Rule so that we can get
|
valuable feedback from our members that are directly impacted by the proposal and help craft a workable solution .
Kindest regards , Kari Hebrank , NUCA Executive Vice Preisdent
• • •
|
NUCA OF FLORIDA |